Ms. Maxwell
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
organization
The government
|
Legal representative |
15
Very Strong
|
68 | |
|
person
MR. EPSTEIN
|
Business associate |
15
Very Strong
|
20 | |
|
person
Epstein
|
Business associate |
13
Very Strong
|
23 | |
|
person
Ms. Sternheim
|
Client |
13
Very Strong
|
11 | |
|
person
Juror No. 50
|
Legal representative |
12
Very Strong
|
35 | |
|
person
Jeffrey Epstein
|
Business associate |
12
Very Strong
|
17 | |
|
person
Mr. Everdell
|
Client |
12
Very Strong
|
12 | |
|
person
Juror No. 50
|
Juror defendant |
12
Very Strong
|
7 | |
|
organization
The government
|
Adversarial |
12
Very Strong
|
16 | |
|
person
Bobbi C. Sternheim
|
Client |
11
Very Strong
|
16 | |
|
person
Judge Nathan
|
Legal representative |
11
Very Strong
|
11 | |
|
person
JANE
|
Alleged perpetrator victim |
11
Very Strong
|
6 | |
|
person
Epstein
|
Co conspirators |
11
Very Strong
|
11 | |
|
organization
GOVERNMENT
|
Legal representative |
11
Very Strong
|
55 | |
|
person
Judge Preska
|
Legal representative |
11
Very Strong
|
10 | |
|
person
JANE
|
Defendant victim |
10
Very Strong
|
6 | |
|
person
Jeffrey Epstein
|
Legal representative |
10
Very Strong
|
5 | |
|
person
Mr. Everdell
|
Legal representative |
10
Very Strong
|
6 | |
|
person
Epstein
|
Financial |
10
Very Strong
|
7 | |
|
organization
GOVERNMENT
|
Adversarial |
10
Very Strong
|
21 | |
|
person
Jeffrey Epstein
|
Association |
10
Very Strong
|
11 | |
|
person
Epstein
|
Friend |
10
Very Strong
|
7 | |
|
person
Jeffrey Epstein
|
Professional |
10
Very Strong
|
9 | |
|
organization
The Court
|
Legal representative |
10
Very Strong
|
10 | |
|
person
Epstein
|
Professional |
10
Very Strong
|
7 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Ms. Maxwell's Sentencing Proceeding | Court | View |
| N/A | N/A | Jury Charge/Instructions regarding circumstantial evidence and inferences. | Courtroom | View |
| N/A | N/A | Jury Selection (Voir Dire) | Courtroom | View |
| N/A | N/A | Detention Hearing Decision | Court | View |
| N/A | N/A | Narrator arrives at Jeffrey's, goes to massage room where Mr. Epstein and Ms. Maxwell are waiting... | Jeffrey's residence, massag... | View |
| N/A | N/A | Request by Daily News to unseal documents related to Ms. Maxwell's new trial effort. | N/A | View |
| N/A | N/A | Took Minor Victim-2 to a movie | Unknown | View |
| N/A | N/A | Sentencing hearing regarding fines, restitution, and guideline calculations. | Courtroom | View |
| N/A | N/A | Period when alleged events took place (described as 'over 25 years ago') | Unknown | View |
| N/A | N/A | Court hearing regarding sentencing enhancements for Ghislaine Maxwell. | Courtroom | View |
| N/A | N/A | Alleged massages of Epstein by Accuser-3 | England | View |
| N/A | N/A | Witness duties regarding household preparation | Epstein Residence | View |
| N/A | N/A | Flight to New Mexico | New Mexico | View |
| N/A | N/A | Court hearing regarding upcoming sentencing and review of the presentence report. | Courtroom (Southern District) | View |
| N/A | N/A | Last bail hearing where the Court expressed concern about lack of ties. | Court | View |
| N/A | N/A | Testimony of Mr. Alessi regarding Ms. Maxwell's use of the telephone directory. | Courtroom (implied) | View |
| N/A | N/A | Ms. Maxwell's forthcoming motion before Judge Nathan. | Court | View |
| N/A | N/A | Jury Charge/Instructions regarding Count Four | Courtroom | View |
| N/A | N/A | Ms. Maxwell visited Mar-a-Lago for potential treatment. | Mar-a-Lago | View |
| N/A | N/A | Acts alleged in Count Four of the Indictment (Transportation of a Minor to Engage in Illegal Sexu... | Not specified | View |
| N/A | N/A | Criminal Trial | District Court | View |
| N/A | N/A | Transportation of Jane in interstate or foreign commerce. | Interstate/International | View |
| N/A | N/A | Sighting of Virginia Roberts | Mar-a-Lago | View |
| N/A | N/A | Spa Check | Mar-a-Lago (Spa) | View |
| N/A | N/A | Three bail renewal hearings | Court | View |
DOJ-OGR-00002911.jpg
This legal document is a letter from attorney Bobbi C. Sternheim to the court, filed on April 7, 2021, concerning her client, Ms. Maxwell. Sternheim argues that the government's public updates on Maxwell's confinement conditions are detrimental, fueling negative media attention and jeopardizing her right to a fair trial. The letter requests that any future updates be limited in scope and filed under seal to protect Ms. Maxwell's privacy.
DOJ-OGR-00002885.jpg
This document is page 2 of a legal filing from the Law Offices of Bobbi C. Sternheim, dated March 31, 2021, regarding the case of United States v. Ghislaine Maxwell. The defense argues that any delay in the trial schedule is the fault of the government for filing a late superseding indictment despite previous assurances (cited from a July 14, 2020 transcript) that they did not anticipate doing so. The defense claims this expansion of the case prejudices Maxwell, prolongs her detention, and transforms the proceedings from a 'two-week' trial into a much longer affair.
DOJ-OGR-00002731.jpg
This legal document, filed on February 16, 2021, is a letter from attorney Bobbi C. Sternheim concerning the detention conditions of her client, Ms. Maxwell. Sternheim argues that Maxwell's harsh treatment at the MDC, including constant surveillance and deprivation, is a detrimental overreaction by the Bureau of Prisons following Jeffrey Epstein's death. The letter claims these conditions are severely impacting Maxwell's health and her ability to prepare for her defense, amounting to what Maxwell feels is "Pretrial Punishment."
DOJ-OGR-00002720.jpg
This document is page 4 of a legal filing, Case 1:20-cr-00330-AJN, filed on February 4, 2021. It contains a series of questions (numbered 27-29) directed at the Government, seeking specific details about allegations against Ms. Maxwell. The questions ask for clarification on who she was allegedly concealing crimes from, the specific acts of abuse she allegedly lied about, and why her statements are considered material to the perjury charges in the Superseding Indictment.
DOJ-OGR-00002718.jpg
This legal document, a "List of Particulars" filed on February 4, 2021, in case 1:20-cr-00330-AJN, is a series of requests for the prosecution to provide specific details about allegations against Ms. Maxwell. The requests seek information such as dates, locations, and specific actions related to Ms. Maxwell's alleged involvement with Jeffrey Epstein in the grooming and sexual abuse of individuals identified as Minor Victim-1 and Minor Victim-2. The document also requests clarification on alleged travel across state lines for the purpose of sexual encounters.
DOJ-OGR-00002710.jpg
This legal document is a motion filed on behalf of Ms. Maxwell in case 1:20-cr-00330-AJN on February 4, 2021. The motion requests the court to order the government to disclose favorable evidence and, more significantly, to hold a pretrial hearing to determine the admissibility of statements from alleged co-conspirators, particularly the deceased Jeffrey Epstein. The defense argues that admitting such testimonial statements without the possibility of cross-examination would be highly prejudicial and cites legal precedents like the 'Geaney rule' to support the need for a prior hearing.
DOJ-OGR-00002703.jpg
This legal document, filed on February 4, 2021, is part of a defense argument for Ms. Maxwell. The defense contends that the indictment is vague and lacks crucial information, citing redacted "flight records" and "diary entries" as examples of information that leads to a dead-end. The filing argues that the absence of specific dates for alleged events, such as when 'Accuser-3' provided massages to Epstein, and the failure to explain how Ms. Maxwell's statements constituted perjury, make it impossible for her to prepare an adequate defense.
DOJ-OGR-00002687.jpg
This legal document, part of a court filing, argues that Ms. Maxwell's alleged conduct with 'Accuser-3' in England falls outside the scope of the charged conspiracy. It cites the case 'United States v. Hsia' as precedent for distinguishing between a core conspiracy and separate acts of concealment or cover-up. The document contends that the object of the conspiracy was to cause individuals to travel for unlawful acts with Epstein, and Maxwell's interactions with Accuser-3 did not further this specific goal.
DOJ-OGR-00002684.jpg
This document is a page from a legal motion filed by the defense in United States v. Ghislaine Maxwell on February 4, 2021. The defense argues that all references to 'Accuser-3' in the indictment should be stricken as 'surplusage' because they are irrelevant to the specific charges of interstate transportation for illegal sexual activity and are unduly prejudicial. The text cites Federal Rule of Criminal Procedure 7(d) and case law to support the argument that these '20-year-old allegations' do not meet the legal requirements for inclusion.
DOJ-OGR-00002683.jpg
This legal document, filed on February 4, 2021, argues against allegations in an indictment concerning Ms. Maxwell's interactions with Accuser-3. The defense contends that the alleged events, including Maxwell introducing Accuser-3 to Epstein, occurred in London between 1994 and 1995, by which time Accuser-3 was 16, the legal age of consent in England. Therefore, the document posits that the alleged "sexual abuse" by Epstein was lawful conduct and cannot be considered an "overt act" in furtherance of a conspiracy, especially as no travel was alleged to have been caused by Maxwell.
DOJ-OGR-00002681.jpg
This legal document, filed on behalf of Ms. Maxwell, argues for the removal of allegations concerning 'Accuser-3' from her indictment. The defense contends that these allegations are irrelevant to the charges of enticing travel for unlawful sexual activity, as there is no claim Accuser-3 ever traveled for such a purpose, and that the alleged activity with Epstein was not unlawful because Accuser-3 was over the age of consent in England. The filing asserts that the government's inclusion of these claims is a prejudicial attempt to demonstrate a propensity for wrongdoing, in violation of federal evidence rules.
DOJ-OGR-00032892.jpg
This Palm Beach Police Department incident report, dated April 20, 2006, documents interviews with Jeffrey Epstein's former employees, Juan and Maria Alessi, conducted on November 21, 2005. The Alessis describe observing numerous young masseuses, some appearing to be sixteen or seventeen, visiting Epstein's home for daily massages. Juan Alessi, the former house manager, also reported finding and cleaning sex toys, including a 'massager/vibrator and a long rubber penis,' in the sink after the massages, providing key witness testimony about the activities occurring at Epstein's residence.
DOJ-OGR-00014480.jpg
This document is a court transcript from case 1:20-cr-00330-PAE, filed on August 10, 2022. In this excerpt, the judge directs Ms. Williams to bring in the jury and then instructs the jury to give their full attention to Ms. Menninger, who is about to deliver the closing argument on behalf of her client, Ms. Maxwell.
DOJ-OGR-00014478.jpg
This is a page from a court transcript (Case 1:20-cr-00330-PAE, United States v. Ghislaine Maxwell) dated August 10, 2022. Defense attorney Mr. Pagliuca objects to the prosecution's closing argument regarding 'grooming-by-proxy' for Jeffrey Epstein; the Judge overrules this, clarifying that while experts couldn't testify to it, lawyers could argue it based on evidence. Prosecutor Ms. Moe then discusses Government Exhibit 52, arguing it demonstrates knowledge and intent because the listed individuals were obviously not 'real masseuses.'
DOJ-OGR-00014477.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) dated August 10, 2022. Defense attorney Mr. Pagliuca requests a mistrial, arguing that the government violated a limiting instruction regarding 'Exhibit 52' (pages from a book) during closing arguments by using hearsay to prove the truth of the matter asserted—specifically linking names in the book to 'sexualized massages' described by a witness named Jane and implying Ms. Maxwell knew the individuals were minors. Pagliuca alternatively requests a curative instruction to the jury.
DOJ-OGR-00005230.jpg
This legal filing from Ms. Maxwell's defense counsel, Bobbi C. Sternheim, argues that Ms. Maxwell's right to prepare her defense has been compromised. The document details how the Government refused to hand-deliver a hard drive of evidence to the Metropolitan Detention Center (MDC), instead using FedEx, and how the MDC then delayed giving the materials to Ms. Maxwell for several days. Counsel requests the Court's intervention due to the MDC's alleged inefficiency and mishandling of legal mail.
DOJ-OGR-00005228.jpg
This legal document is a letter dated October 14, 2021, from attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan. The letter informs the court of the defense's intent to file a Rule 412 motion on behalf of Ms. Maxwell by November 15, 2021. It justifies this timeline by stating it is essential for counsel to adequately consult with their client and prepare the necessary legal research and procedures.
DOJ-OGR-00005227.jpg
This document is page 2 of a legal filing addressed to Judge Alison J. Nathan regarding the case of Ms. Maxwell. The defense counsel argues against the government's proposed deadline for a Rule 412 motion, requesting more time to review over 8,000 pages of recently disclosed material and witness information. The defense asserts that a deadline before November 15 is unreasonable given the volume of new evidence and the defendant's custodial status.
DOJ-OGR-00005204.jpg
This legal document, filed on October 12, 2021, in the Southern District of New York, is a joint request from the prosecution (Government) and the defense to the Court. Both parties ask that only jurors with availability beyond the Christmas holiday be selected for the trial. The defense estimates its case will last approximately two weeks but notes this may change after reviewing late-night disclosures from the Government, which the defendant, Ms. Maxwell, had not yet received due to delivery issues at the MDC.
DOJ-OGR-00002790.jpg
This document page argues for the release of Ms. Maxwell on bail, asserting that proposed conditions, including renouncing foreign citizenship and strict asset monitoring, are sufficient to mitigate flight risk. It contends that her continued detention is prejudicial, impairing her physical health and ability to prepare for trial, while a footnote details specific issues with discovery access, mail delays, and unsafe visiting conditions at the MDC.
DOJ-OGR-00002788.jpg
This legal document, filed on March 23, 2021, argues that the government's case against Ms. Maxwell is weakening, thereby diminishing her flight risk. The filing points to several weaknesses, including a 2007 Non-Prosecution Agreement with Jeffrey Epstein that may immunize Maxwell, the government's concession that it cannot prove Maxwell or Epstein caused 'Accuser-3' to travel, and evidence that prosecutors misled a judge. The document suggests that despite the government's escalating claims about her flight risk, the deteriorating case against her warrants a reevaluation of her detention.
DOJ-OGR-00002785.jpg
This document is page 5 of a legal filing (Document 171) from the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on March 23, 2021. The defense argues that Maxwell is not a flight risk because she is willing to renounce both her French and British citizenships and waive extradition rights. The text cites a legal opinion by Mr. Julié regarding French extradition law (Article 696-4) to support the claim that she would not be protected from extradition if she fled to France after renouncing citizenship.
DOJ-OGR-00002783.jpg
This page from a legal document outlines proposed bail conditions for Ms. Maxwell, including 24/7 private security and strict supervision by Pretrial Services. It argues against the government's opposition to bail and asserts that the District Court retains jurisdiction to decide on the matter despite a pending appeal in the Second Circuit.
DOJ-OGR-00008812.jpg
This document is page 2 of a court filing from January 10, 2022, in the case against Ghislaine Maxwell. It outlines the defense's position requesting a delay in sentencing due to a motion for a new trial based on misconduct by Juror #50. The defense argues that participating in a presentence investigation would violate Maxwell's Fifth Amendment rights while the motion for a retrial is pending.
DOJ-OGR-00008806.jpg
This legal document, dated January 5, 2022, is a filing in Case 1:20-cr-00330-PAE, addressed to The Honorable Alison J. Nathan. It indicates that Ms. Maxwell (Ghislaine Maxwell) suggests examining deliberating jurors to evaluate their conduct and is in the process of drafting a Rule 33 motion. The document lists several attorneys and their respective law firms representing Ghislaine Maxwell.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| N/A | Received | Epstein | Ms. Maxwell | $10,000,000.00 | Bequest from estate | View |
| N/A | Paid | Ms. Maxwell | Court | $0.00 | Judge intends to impose a fine. | View |
| N/A | Received | Epstein | Ms. Maxwell | $10,000,000.00 | Bequest listed as an asset | View |
| N/A | Paid | Ms. Maxwell | Government/Victims | $0.00 | Restitution (Government is not seeking restitut... | View |
| N/A | Paid | Ms. Maxwell | Unspecified | $0.00 | Sale of 69 Stanhope Mews and purchase of Kinner... | View |
| N/A | Received | Jeffrey Epstein | Ms. Maxwell | $0.00 | Purchase of a large townhouse. | View |
| N/A | Received | Epstein | Ms. Maxwell | $23,000,000.00 | Transfer of funds confirmed by bank statements. | View |
| 2023-06-29 | Paid | Ms. Maxwell | Court/Government | $0.00 | Discussion regarding a court-imposed fine and M... | View |
| 2022-07-22 | Paid | Ms. Maxwell | the government | $0.00 | Judge intends to impose a fine; amount not spec... | View |
| 2021-03-22 | Paid | Ms. Maxwell | Attorney Escrow A... | $0.00 | Funds for legal services presently held in atto... | View |
| 2021-02-23 | Paid | Ms. Maxwell | Court | $0.00 | Proposed bond (amount not specified on this pag... | View |
| 2021-02-23 | Paid | Ms. Maxwell | Escrow | $0.00 | Money currently held in escrow for legal fees. | View |
| 2020-12-01 | Paid | Ms. Maxwell | N/A | $22,000,000.00 | Reported assets in support of bail application. | View |
| 2020-07-01 | Paid | Ms. Maxwell | N/A (Reporting) | $3,800,000.00 | Assets reported by Maxwell in July 2020 | View |
| 2020-07-01 | Paid | Ms. Maxwell | N/A | $3,800,000.00 | Assets reported by Ms. Maxwell in July 2020 | View |
| 2020-01-01 | Paid | Ms. Maxwell | N/A | $22,000,000.00 | Assets reported in support of bail application. | View |
| 1997-01-01 | Received | Unknown | Ms. Maxwell | $0.00 | Deal closed for leasehold property. | View |
| 1997-01-01 | Paid | Ms. Maxwell | Mr. and Mrs. O'Neill | $0.00 | Closing of the deal for property sale. | View |
| 1996-01-01 | Received | Unknown | Ms. Maxwell | $0.00 | Contracts exchanged for leasehold property. | View |
| 1996-01-01 | Paid | Ms. Maxwell | Mr. and Mrs. O'Neill | $0.00 | Exchange of contracts for property sale. | View |
Legal consultation
Guards are described as feverishly writing while observing Ms. Maxwell during videoconferencing with her counsel.
Performance of duties at the residence
Ms. Maxwell provided instructions to Alessi regarding his duties at the residence, which involved tasks in various rooms and areas of the property.
Upcoming flight on one of Mr. Epstein's planes
After beepers were no longer used, Ms. Maxwell would contact the witness via cell phone to provide information about an upcoming flight.
Declaration and notice of motion to withdraw
HMF served a copy of the declaration and notice of motion to withdraw on Ms. Maxwell via her new counsel, Mr. Markus.
Newspaper
Received a copy of the New York Times issued in October.
Confirmation of decision not to testify
Judge asks Maxwell directly if it is correct that she has decided not to testify.
Attorney Glassman
A letter from Ms. Maxwell's side regarding the testimony of Attorney Glassman.
Exhibit List
Counsel hand-delivered and deposited exhibit list in the MDC legal mailbox.
Waiver Form Review
Attorneys read the waiver form to Maxwell and received authorization to sign on her behalf.
Request for production of discovery materials
Ms. Maxwell sent a detailed letter requesting the production of discovery materials under Rule 16 of the Federal Rules of Criminal Procedure, Brady v. Maryland, and Giglio v. United States. The Government has not yet responded.
Request to stay unsealing process
Maxwell asked for a stay claiming awareness of critical new information but could not disclose details due to a protective order.
Denial of stay
Judge Preska declined to stay the unsealing but offered to reevaluate if Judge Nathan modified the protective order.
Request for leave to be excused from publicly filing a re...
This document is a filing by Ms. Maxwell requesting permission to not publicly file a redacted version of Appendix Volume 2, citing confidential material under a criminal protective order related to two ongoing appeals.
Modification of protective order
Request to share information with other judicial officers under seal.
No Subject
Ms. Maxwell used the phone subscribed to 'Terramar Project, Inc.' to make calls as late as May 2020.
No Subject
Ms. Maxwell used the phone subscribed to "Terramar Project, Inc." to make calls as late as May 2020.
Sex toys at Palm Beach house
Maxwell denied recalling sex toys at Epstein's house.
Civil Defamation Action
Testimony provided under oath involved in the perjury counts.
Recruitment of underage girls
Maxwell denied knowing about a scheme to recruit underage girls.
Civil Defamation Action
Testimony provided under oath involved in the perjury counts.
Civil Depositions
Two civil depositions where Maxwell allegedly made materially false statements.
Epstein investigation
Ms. Maxwell called an individual living outside of Sydney to inform them that Mr. Epstein was being investigated and that if they refused to cooperate, they'd be 'taken care of'.
Request for call back
"TELL HIM TO CALL ME"
Called, not important
A message for Mr. Epstein from Ms. Maxwell, taken at 7:44 AM, stating she "CALLED BUT NOT VERY IMPORTENT".
Called but not very important
At 7:44 AM, Ms. Maxwell called for Mr. Epstein, leaving a message that the call was not very important.
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