GOVERNMENT

Organization
Mentions
2805
Relationships
178
Events
870
Documents
1344
Also known as:
Government of Australia Government of the Republic of Cyprus United States Government Accountability Office (GAO) Office of Government Relations PRC Government US Government (The Americans) Government Exhibit Office of Government Information Services Government / USA Orban Government Palestinian government IRS Tax Exempt and Government Entities Division (IRS-TEGE) Hamas Government Saudi Arabian government Orange County, California (Government) Netanyahu government British Government American government Pakistan Government/Military Canadian Government Australian government Government of Ecuador New Zealand Government Government of the U.S. Virgin Islands Gov't (Government) Government / DOJ American Federation of Government Employees/Council of Prison Locals United States of America (Government) US Government (implied by SDNY context)

Relationship Network

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Interactive Network: Click nodes or edges to highlight connections and view details with action buttons. Drag nodes to reposition. Node size indicates connection count. Line color shows relationship strength: red (8-10), orange (6-7), yellow (4-5), gray (weak). Use legend and help buttons in the graph for more guidance.
178 total relationships
Connected Entity Relationship Type
Strength (mentions)
Documents Actions
person MAXWELL
Legal representative
15 Very Strong
29
View
organization Defense
Legal representative
13 Very Strong
21
View
person defendant
Legal representative
13 Very Strong
62
View
person Defense counsel
Legal representative
12 Very Strong
14
View
person GHISLAINE MAXWELL
Legal representative
12 Very Strong
14
View
person Ms. Maxwell
Legal representative
11 Very Strong
55
View
person Recipient
Legal representative
11 Very Strong
5
View
organization Defense
Adversarial
11 Very Strong
10
View
person MAXWELL
Adversarial
10 Very Strong
14
View
person the defendant
Legal representative
10 Very Strong
6
View
person THOMAS
Legal representative
10 Very Strong
9
View
person Defense counsel
Professional
10 Very Strong
6
View
person Ms. Maxwell
Adversarial
10 Very Strong
21
View
person the defendant
Adversarial
10 Very Strong
7
View
person defendant
Adversarial
10 Very Strong
24
View
location court
Legal representative
10 Very Strong
5
View
person Ms. Comey
Professional
9 Strong
4
View
person MR. ROHRBACH
Professional
8 Strong
4
View
organization Defense
Professional
8 Strong
3
View
person MR. EPSTEIN
Legal representative
7
2
View
person Thomas
Legal representative
7
3
View
person Dr. Rocchio
Professional
7
2
View
person Minor Victims
Protective
7
2
View
person Epstein's counsel
Professional
7
2
View
person Ms. Moe
Professional
7
3
View
Date Event Type Description Location Actions
N/A Legal dispute The defense is arguing that the government must produce unredacted reports containing Brady mater... Court View
N/A Legal agreement The signing of a Non-Prosecution Agreement (NPA) related to the Epstein case. N/A View
N/A Legal hearing A detention hearing held by the district court where the government argued Ms. Maxwell was a flig... district court View
N/A Trial testimony Anticipated testimony of Witness-3 regarding interactions with the Defendant and Mr. Epstein. Courtroom View
N/A Court ruling A judge makes several rulings on objections from the government and defense regarding the admissi... Courtroom View
N/A Trial The document discusses the government's burden of proof at Ms. Maxwell's upcoming trial. N/A View
N/A Legal proceeding The criminal trial of Ms. Maxwell, where she is the defendant. N/A View
N/A Legal action The government's decision to intervene in the case Doe v. Indyke. S.D.N.Y. View
N/A Legal action The government's decision to remain on the sidelines of the case Giuffre v. Maxwell. N/A View
N/A Legal proceeding A criminal case involving Ms. Maxwell where the government insists on the secrecy of discovery ma... N/A View
N/A Legal proceeding Ms. Maxwell's prosecution, which she argues was barred by a non-prosecution agreement (NPA). District Court View
N/A Legal challenge Schulte's fair cross-section challenge to the jury-selection process, alleging systematic exclusi... N/A View
N/A Legal proceeding The Government sought an Indictment in White Plains. White Plains View
N/A Hearing A court hearing where Juror 50 testified about his inaccurate answers on a questionnaire. Court View
N/A Legal proceeding Oral argument during which the government was asked about the routine nature of shining lights in... Court View
N/A Investigation The Government continued its investigation, which included interviewing two victims. N/A View
N/A N/A Post-verdict hearing regarding Juror 50 District Court View
N/A Investigation The Government opened a grand jury investigation into Jeffrey Epstein and his possible co-conspir... N/A View
N/A Legal action Grand jury subpoenas were issued to an entity referred to as 'Recipient'. N/A View
N/A Legal hearing The original bail hearing where the Government argued the defendant has considerable financial re... Court View
N/A Trial A legal trial where evidence was presented, a summation was given by the Government, and jury ins... District Court View
N/A Legal proceeding A Grand Jury Proceeding, the disclosure of materials from which is being debated based on several... N/A View
N/A Legal proceeding The Government began to produce discovery shortly after the protective order was entered. N/A View
N/A Legal proceeding The Government began to produce discovery materials to the Defendant shortly after the protective... N/A View
N/A Court proceeding The initial stage of the case, opening statements, is scheduled to begin after lunch. courtroom 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.

Legal court document (jury instructions)
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20

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.'

Court filing / jury instructions
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20

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.

Court filing (jury instructions)
2025-11-20

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.

Court filing - jury instructions
2025-11-20

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.

Legal document
2025-11-20

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.

Court filing / jury instructions
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document (jury instructions)
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20

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.

Legal filing (motion for bill of particulars)
2025-11-20
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