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 | Sale of London Home | London | View |
| N/A | N/A | Initial sexual interaction/abuse of Jane (age 14). | Unknown | View |
| N/A | N/A | Recruitment of massage therapists. | Legitimate hotels | View |
| N/A | Detention | Ms. Maxwell's period of detention has passed the nine-month mark. | N/A | View |
| N/A | Legal proceeding | Ms. Maxwell challenged the strength of the government's case in pretrial motions pending before t... | N/A | View |
| N/A | Law enforcement action | FBI agents walked up the driveway to Ms. Maxwell's house, leading to her being alerted and moving... | the house | View |
| N/A | Legal proceeding | An initial bail hearing where an explanation was given for why Ms. Maxwell's phone was wrapped in... | Court | View |
| N/A | Legal discovery review | Defense counsel conducted an evidence view with Ms. Maxwell over the past three days to review ph... | N/A | View |
| N/A | N/A | Grooming activities (movies and shopping). | Unknown | View |
| N/A | Trial | A trial in which the jury is being instructed on how to evaluate witness testimony. | N/A | View |
| N/A | Legal action | Ms. Maxwell objected to the government’s Confidential designation under paragraph 9 of the Protec... | N/A | View |
| N/A | Legal action | Ms. Maxwell requested that the government withdraw the 'Confidential' designation. | N/A | View |
| N/A | Mistreatment | Ms. Maxwell is allegedly being subjected to harsh prison conditions, including constant flashligh... | prison | View |
| N/A | Jury selection (voir dire) | The process of screening prospective jurors for Ms. Maxwell's trial, during which Juror No. 50 al... | Court | View |
| N/A | Claim | The witness, Jane, made a claim against Ms. Maxwell through a claims program. | N/A | View |
| N/A | Trial | A contested trial of Ms. Maxwell where the central issue was the credibility of the accusers. The... | N/A | View |
| N/A | Jury selection | During jury selection (voir dire) for Ms. Maxwell's trial, Juror 50 failed to disclose his claime... | N/A | View |
| N/A | N/A | Delivery of Instruction No. 36 regarding Conspiracy to Violate Federal Law. | Courtroom | View |
| N/A | Testimony | Mr. Pagliuca summarizes testimony from four witnesses (Carolyn, Jane, Kate, Mr. Alessi) regarding... | Courtroom | View |
| N/A | Legal proceeding | Ms. Maxwell's trial, which is the subject of a motion for a new trial. | N/A | View |
| N/A | Hearing | A proposed evidentiary hearing regarding Juror No. 50, which is being debated by the government a... | N/A | View |
| N/A | Alleged criminal act | Ms. Maxwell encouraging Jane to travel across state lines with the intent that she engage in ille... | Across state lines | View |
| N/A | Transition of duties | Sarah Kellen took over the responsibility of scheduling massage appointments from Ms. Maxwell. | N/A | View |
| N/A | Trip | Alleged transportation of 'Jane' from Florida to New York, arranged by Ms. Maxwell. | from Florida to New York | View |
| N/A | Travel | An unnamed male subject frequently traveled with assistants and a gourmet chef. | N/A | View |
DOJ-OGR-00002327(1).jpg
This legal document argues that the defendant, Ms. Maxwell, was denied her Sixth Amendment right to a grand jury selected from a fair cross-section of the community. It cites a parallel case, U.S. v. Balde, and an expert analysis by Jeffrey Martin, which found significant underrepresentation of Black and Hispanic individuals in the White Plains jury wheel. Because Ms. Maxwell's grand jury was drawn from the same pool, the document contends this analysis applies to her case as well.
DOJ-OGR-00002325.jpg
This document is page 5 of a legal filing (Statement of Facts) dated January 25, 2021, arguing that Ghislaine Maxwell's indictment should be dismissed due to Sixth Amendment violations. The defense contends that while the alleged crimes occurred at Epstein's Manhattan residence, the government improperly used a grand jury from White Plains due to COVID-19 protocols, deviating from established practice.
DOJ-OGR-00002325(1).jpg
This document is page 5 of a legal filing (Statement of Facts) dated January 25, 2021, arguing that Ghislaine Maxwell's indictment should be dismissed due to Sixth Amendment violations. The defense contends that while the alleged crimes occurred at Epstein's Manhattan residence, the government improperly used a grand jury from White Plains due to COVID-19 protocols, deviating from established practice.
DOJ-OGR-00002317.jpg
This document is the conclusion of a legal filing dated January 25, 2021, submitted by the attorneys for Ghislaine Maxwell. The attorneys argue that the indictment lacks the necessary specificity for Maxwell to prepare an adequate defense for Counts One through Four, violating her Fifth and Sixth Amendment rights. They request that the court either dismiss these counts or compel the government to provide a Bill of Particulars and further discovery.
DOJ-OGR-00002317(1).jpg
This legal document, dated January 25, 2021, is a memorandum filed in support of a motion for a Bill of Particulars and Pretrial Disclosures in the case against Ms. Maxwell. It argues that the indictment lacks specificity regarding alleged 'grooming' acts, violating her constitutional rights, and requests either the dismissal of certain counts or that the government provide more detailed information for her defense. The document is signed by several attorneys representing Ghislaine Maxwell.
DOJ-OGR-00002316(1).jpg
This legal document, part of a filing on behalf of Ms. Maxwell, argues that the indictment against her is unconstitutionally vague. It claims the inconsistent use of terms like "minor victims" and "girls," combined with a lack of specific dates for alleged crimes from decades ago, prevents Maxwell from preparing an adequate defense. The filing asserts this vagueness makes it impossible to investigate the allegations or challenge the prosecution's evidence effectively at trial.
DOJ-OGR-00002315.jpg
This legal document, filed on January 25, 2021, argues that the indictment against Ms. Maxwell lacks sufficient specificity regarding the alleged crimes and the identities of accusers/victims. It contends that the open-ended time periods and vague descriptions of 'minor girls' or 'victims' in the indictment make it impossible for Ms. Maxwell to prepare an adequate defense or apply the statute of limitations. The document cites legal precedents to support the argument for greater specificity in criminal charges.
DOJ-OGR-00002315(1).jpg
This legal document is a court filing arguing that the indictment against Ms. Maxwell is insufficient for her to prepare a defense. The filing claims the indictment uses vague, open-ended time periods for the alleged crimes (e.g., 'from at least in or about 1994') and fails to specifically identify the accusers, referring to them with general terms like 'minor girls' and 'victims'. This vagueness, the document argues, makes it impossible to apply the statute of limitations or know who the government considers a victim.
DOJ-OGR-00002314.jpg
This legal document, filed on January 25, 2021, is an argument on behalf of Ms. Maxwell to dismiss the Superseding Indictment against her. The defense claims the indictment is unconstitutionally vague because it fails to specify dates for the alleged crimes beyond a broad '1994-1997' range and lacks specific details, thereby preventing Ms. Maxwell from preparing an adequate defense. The filing requests the Court to either dismiss counts one through four of the indictment or compel the Government to provide a Bill of Particulars with more specific information.
DOJ-OGR-00002314(1).jpg
This document is a page from a legal motion filed on January 25, 2021, in the case of United States v. Ghislaine Maxwell. The defense argues that the Superseding Indictment is vague, failing to identify specific accusers or dates beyond the range of 1994-1997. The filing requests that the Court dismiss Counts One through Four or force the Government to provide a Bill of Particulars, citing Federal Rule of Criminal Procedure 7(c)(1) and Constitutional precedents regarding due process.
DOJ-OGR-00002303(1).jpg
This legal document, filed on January 25, 2021, is a motion from Ms. Maxwell requesting the Court to dismiss Count One or Count Three of her Superseding Indictment. She argues that these counts are multiplicitous, charging the same offense twice, and thus violate the Double Jeopardy Clause of the Fifth Amendment. The document cites legal precedents to define multiplicity and explain its dangers.
DOJ-OGR-00002294.jpg
This legal document argues against including perjury counts in Ms. Maxwell's criminal trial. The author contends that doing so would force the relitigation of a complex and unresolved civil defamation case (dismissed in 2017), making the current trial unnecessarily long and confusing. Furthermore, it raises the issue that including these counts could force Ms. Maxwell's long-term lawyers to testify, potentially leading to their disqualification from the case.
DOJ-OGR-00002293.jpg
This legal document, part of a court filing, presents an argument from Ms. Maxwell's defense against the joinder of Perjury Counts with Mann Act Counts in her indictment. The defense contends that this joinder would prejudice the jury and that the government is strategically manipulating the timeframes of the alleged conduct (1994-1997) to avoid the legal implications of Epstein's 2007 Non-Prosecution Agreement, which the government claims only covers conduct from 2001-2007.
DOJ-OGR-00002293(1).jpg
This legal document, filed on January 25, 2021, presents an argument from Ms. Maxwell's defense. The defense argues against the joinder of Perjury Counts with Mann Act Counts, asserting it would create a substantial risk of jury confusion and prejudice Ms. Maxwell. The document also accuses the government of strategically limiting the charges to the 1994-1997 period to avoid the legal implications of Epstein's 2007 Non-Prosecution Agreement, while simultaneously trying to introduce conduct from a later period.
DOJ-OGR-00002291.jpg
This page from a legal filing argues that Perjury Counts against Ms. Maxwell should not be joined with Mann Act Counts under Rule 8(a) because the connection is illogical, and that they should be severed under Rule 14(a) to prevent substantial prejudice. The defense contends that the perjury charges stem from confusing questions in a separate defamation lawsuit and that a joint trial would improperly force the re-litigation of that civil matter.
DOJ-OGR-00002291(1).jpg
This page from a legal filing argues that Perjury Counts against Ms. Maxwell should not be joined with Mann Act Counts under Rule 8(a) because the connection is illogical, and that they should be severed under Rule 14(a) to prevent substantial prejudice. The defense contends that the perjury charges stem from confusing questions in a separate defamation lawsuit and that a joint trial would improperly force the re-litigation of that civil matter.
DOJ-OGR-00002290(1).jpg
This document is page 12 of a defense filing (Document 120) from January 2021 in the case United States v. Ghislaine Maxwell. The text argues against the 'joinder' (combining) of Perjury Counts with Mann Act Counts, stating that Maxwell's alleged false statements in 2016 civil depositions were tangential to the defamation case and not part of a 'common scheme' to obstruct the Mann Act investigation. The defense distinguishes this case from legal precedent (Potamitis), emphasizing that Maxwell did not lie to the FBI or a Grand Jury to derail an investigation.
DOJ-OGR-00002285.jpg
This document is page 7 of a legal filing (Document 120) from January 25, 2021, in the case against Ghislaine Maxwell. It outlines Counts Five and Six of the indictment, which allege perjury stemming from two civil depositions given by Maxwell in 2016. The text primarily discusses 'Applicable Law' regarding the 'Joinder of Offenses' under Rule 8(a) of the Federal Rules of Criminal Procedure, citing various legal precedents to justify joining separate offenses in a single indictment for trial efficiency.
DOJ-OGR-00002285(1).jpg
This legal document, part of case 1:20-cr-00330-AJN filed on January 25, 2021, addresses the perjury counts (Five and Six) against Ms. Maxwell. It alleges she testified falsely in two separate civil depositions on April 22, 2016, and July 22, 2016. The document then lays out the applicable law regarding the joinder of offenses under Rule 8(a) of the Federal Rules of Criminal Procedure, citing case law to explain the balance between trial efficiency and potential prejudice to the defendant.
DOJ-OGR-00002283(1).jpg
This document is an introduction to a legal motion filed by Ghislaine Maxwell's defense on January 25, 2021, requesting the severance of perjury charges (Counts Five and Six) from sex trafficking charges (Counts One through Four). The defense argues that joining these counts causes substantial prejudice because the perjury charges stem from a 2016 civil defamation suit involving Virginia Roberts Giuffre, whose allegations the defense characterizes as false and financially motivated. The document contends that Giuffre is not one of the accusers in the primary trafficking counts and that introducing her testimony would improperly influence the jury regarding conduct alleged to have occurred between 1994 and 1997.
DOJ-OGR-00002280.jpg
This document is the table of contents for a legal filing in Case 1:20-cr-00330-AJN, filed on January 25, 2021. The filing outlines arguments concerning the joinder and severance of offenses, specifically distinguishing between "Mann Act Counts" and "Perjury Counts," and argues that the perjury counts should be severed to avoid substantially prejudicing Ms. Maxwell at trial.
DOJ-OGR-00002280(1).jpg
This document is the table of contents for a legal filing in Case 1:20-cr-00330-AJN, filed on January 25, 2021. The filing outlines arguments concerning the joinder and severance of offenses against Ms. Maxwell, specifically distinguishing between "Mann Act Counts" and "Perjury Counts," and argues that the perjury counts should be severed to avoid prejudicing her at trial.
DOJ-OGR-00002262.jpg
This legal document is a letter dated January 8, 2021, from attorney Christian R. Everdell to Judge Alison J. Nathan. Everdell requests a 30-day extension to file a notice of appeal regarding the denial of his client, Ms. Maxwell's, renewed motion for bail, arguing it would promote judicial efficiency. Judge Nathan denied the request in a handwritten note dated January 11, 2021, stating that sufficient cause for the extension had not been provided.
DOJ-OGR-00002260.jpg
This legal document is the second page of a letter dated January 8, 2021, from attorney Christian R. Everdell to Judge Alison J. Nathan. Everdell requests a 30-day extension for his client, Ms. Maxwell, to file a notice of appeal against the court's December 28, 2020 order denying her bail. The letter argues the extension would promote judicial efficiency and notes that the government objects to the request.
DOJ-OGR-00002249.jpg
This legal document, part of a court filing from December 30, 2020, discusses a bail application for a defendant, Ms. Maxwell. It recounts that the Court initially found her financial disclosures incomplete, but she has since provided a more detailed report from a UK accounting firm, Macalvins, and a review by a former IRS agent. Despite the new information, the Court remains unpersuaded that the proposed bail package, secured by $8 million in property and $500,000 in cash, would reasonably assure her appearance in court.
| 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 Emails
Legal emails prematurely deleted by MDC in violation of policy.
Upcoming flight on one of Mr. Epstein's planes
Ms. Maxwell would contact the witness via beeper to provide information about an upcoming flight.
Discovery Disc
Federal Express envelope containing an unreadable discovery disc, delayed by two weeks.
Video conference
Session reduced by 90 minutes; severe audio/video technical issues impacting confidentiality and visibility.
In-person legal conference
Four-hour legal conference marked by restrictions on water, earbuds, and privacy.
Discovery relevant to motions
Ms. Maxwell asked the government for documents relevant to these motions, but was denied.
Press approaching the house
The security guard radioed Ms. Maxwell to alert her that he believed the press was on the grounds and approaching the house.
Location tracking
Government located Maxwell by tracking her primary phone.
Divorce
Discussed divorce to create distance and protect him from consequences of association.
Video conference
Monitor repositioned further away, impacting document review.
Discovery in Giuffre v. Maxwell
Two depositions designated confidential.
Legal Emails
MDC allegedly prematurely deleted legal emails.
Missed Call
Telephoned / Please Call
Civil Deposition
Testimony where the judge concluded dishonesty/perjury occurred.
Status/Indictment
Maxwell stayed in contact with the government, allegedly to stave off indictment, but did not provide whereabouts.
Legal Defense
Meetings behind closed doors, visible but not audible to staff.
Phone Message
Telephoned. (No specific message text written)
General communication
Communication via cell phones
Pretrial motions
Request for a legal call to confer with counsel regarding pretrial motions was denied.
Legal Defense
Facilitated on-going communication.
Rules and Regulations
Guards were the sole source of information; Maxwell was instructed not to speak to them lest she face disciplinary sanction.
Needs/requests
Communication via beeper if she needed something
Discovery Disc
Federal Express envelope containing an unreadable discovery disc.
Defense Preparation
Reference to Maxwell's need to communicate freely with counsel to prepare for defense.
Upcoming flight information
Ms. Maxwell would contact the witness (Rodgers) via beeper to convey information about upcoming flights on Mr. Epstein's planes.
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