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-00010481.jpg
This legal document argues that the harsh conditions of Ms. Maxwell's 22-month pretrial detention, described as 'supermax-type' and 'de facto solitary confinement', should be factored into her sentencing. Citing the principle of proportionality, the filing requests a 'hard-time credit' for this unusual hardship and references compensation laws for the wrongfully convicted to illustrate the severity of her confinement.
DOJ-OGR-00010479.jpg
This legal document, filed on June 15, 2022, argues that Ms. Maxwell is entitled to a significant downward variance in her sentence. The argument is based on the extraordinary hardship she endured during her pretrial detention, which occurred entirely during the COVID-19 pandemic and amounted to solitary confinement. The filing cites legal precedents, such as United States v. Gonzalez and United States v. Brissett, where courts have granted 'hard-time credit' for similar punitive conditions.
DOJ-OGR-00010478.jpg
This legal document, a page from a court filing, argues that the harsh conditions of incarceration during the COVID-19 pandemic should be considered a mitigating factor for sentencing. It cites multiple precedents from the Southern District of New York (S.D.N.Y.) to support the claim that the pandemic, with its associated lockdowns and health risks, has made prison time significantly more punitive than under normal circumstances. The argument is made in the context of a defendant, Ms. Maxwell, to warrant a downward variance in her sentence.
DOJ-OGR-00010476.jpg
This legal document, part of case 1:20-cr-00330-PAE filed on June 15, 2022, argues that the pre-sentence detention conditions of Ms. Maxwell at the MDC constitute cruel and unusual punishment in violation of the Eighth Amendment. The filing claims her treatment is significantly harsher than that of the general prison population and was implemented under specific directives from then-Attorney General William Barr, who was intent on avoiding a repeat of the incident involving Epstein in BOP custody. The document asserts this disparate and punitive treatment was condoned by MDC supervisors and wardens.
DOJ-OGR-00010473.jpg
This document is an excerpt from a legal filing (Document 663, filed 06/15/22) titled "Professional Assessment of Impact of Conditions of Confinement." It details a report by Dr. Alexander Sasha Bardey, an independent forensic psychiatrist, who evaluated Ms. Maxwell from October 2020 to August 2021. The report concludes that Ms. Maxwell's ability to cope with legal proceedings and participate in her defense is being eroded due to her solitary confinement conditions, an observation corroborated by Ms. Saffian.
DOJ-OGR-00010472.jpg
This legal document details the allegedly poor and dehumanizing conditions of Ms. Maxwell's pre-trial detention. It argues that inadequate nutrition, sleep deprivation, psychological threats, and significant technical difficulties with discovery materials severely weakened her and thwarted her ability to prepare her defense. The document suggests these conditions were intentionally imposed to satisfy various government and legal parties following Epstein's death.
DOJ-OGR-00010469.jpg
This document page, filed on June 15, 2022, details the strict confinement conditions of Ghislaine Maxwell. It describes her total isolation from other inmates, 24-hour surveillance by high-level BOP staff (including while showering), and sleep deprivation tactics such as constant lighting and flashlight checks every 15 minutes. A footnote highlights the 'enormous expenditure' of this individualized detention for a non-violent inmate.
DOJ-OGR-00010464.jpg
This document is page 17 (PDF page 18) of a sentencing memorandum filed on June 15, 2022, in the case of United States v. Ghislaine Maxwell. It outlines the legal standards for sentencing under 18 U.S.C. § 3553(a), citing Supreme Court precedents like Gall and Nelson. The text argues that these statutory factors, specifically the need for just punishment and Ms. Maxwell's history, weigh heavily in favor of the proposed sentence.
DOJ-OGR-00010460.jpg
This legal document, filed on June 15, 2022, details the accomplishments and character of Ms. Ghislaine Maxwell. It highlights her professional achievements, including becoming an EMT and pilot, and her philanthropic work, such as founding The TerraMar Project in 2012, which was later closed after Epstein's death. The document also references letters from family, including siblings Anne Halve and Philip Maxwell, and friends that aim to counter her negative public image.
DOJ-OGR-00010455.jpg
This document, identified as part of a Presentence Investigation Report, details a recommendation by Probation on June 9, 2022, for a 240-month imprisonment sentence for Ms. Maxwell, followed by five years of supervised release. It outlines mitigating factors, including her age, philanthropic history with organizations like the Clinton Global Initiative and The TerraMar Project, and her activities during incarceration, such as completing courses and tutoring inmates. The document also notes Ms. Maxwell's intention to appeal her conviction.
DOJ-OGR-00010453.jpg
This legal document argues that Ms. Maxwell was not a flight risk despite her foreign nationalities and remained in the United States after Epstein's death. It states her presence in New Hampshire was for her own protection and that her lawyers were in contact with prosecutors for a self-surrender. The document contends that her detention on July 6, 2020, and subsequent denial of four bail applications were based on an unfounded claim of flight risk by the government.
DOJ-OGR-00010442.jpg
This legal document, part of a court filing from June 15, 2022, argues against applying a sentencing enhancement for 'undue influence'. The text asserts that the evidence does not support the claim that a witness named Carolyn was unduly influenced by Epstein or Ms. Maxwell. To support this, it cites Carolyn's own testimony that she actively sought out massage appointments, recruited other minors for money, and refused offers to travel to Epstein's island, indicating her actions were voluntary.
DOJ-OGR-00010438.jpg
This legal document, page 21 of a court filing, argues that Ms. Maxwell should not receive an aggravating role enhancement because she did not supervise other criminal participants. It specifically refutes the idea that she supervised Sarah Kellen, presenting testimony from Cimberly Espinosa that Kellen was hired by Epstein to replace Maxwell's duties, not to work under her. The document also states that other employees, like pilots Larry Visoski and David Rodgers, had no knowledge of any criminal conduct.
DOJ-OGR-00010437.jpg
This legal document, filed on June 15, 2022, argues that Ms. Maxwell should not receive an aggravating role sentencing enhancement under USSG § 3B1.1. The core argument is that there is no evidence she supervised any other criminal participant in the offenses involving victims like 'Jane' and Annie Farmer. In fact, the document asserts that the trial record shows Ms. Maxwell was directed and managed by Epstein, making her ineligible for the enhancement.
DOJ-OGR-00010435.jpg
This legal document, filed on June 15, 2022, argues against applying the sentencing guideline § 4B1.5 to Ms. Maxwell. The author contends that the guideline is intended only for recidivist sex offenders who pose a continuing danger to the public, which they claim Ms. Maxwell is not. Applying the guideline would allegedly contradict the intent of Congress and the Sentencing Commission, improperly add over 10 years to her sentence, and lead to an absurd result.
DOJ-OGR-00010425.jpg
This legal document, part of a court case, argues against the application of the 2004 Sentencing Guidelines for a defendant whose criminal conduct is alleged to have ended 'in or about 2004'. The filing contends that applying the later, harsher guidelines would be an ex post facto violation, as the jury never made a specific factual finding that the conduct continued past the 2004 Guidelines' effective date. It further argues that having the court, rather than the jury, determine the offense end date would violate the defendant's (Ms. Maxwell's) Sixth Amendment rights.
DOJ-OGR-00010424.jpg
This legal document, part of a court filing, argues that Ms. Maxwell must be sentenced under the 2003 Guidelines rather than the harsher 2004 Guidelines. It asserts that applying the 2004 Guidelines would violate the Ex Post Facto Clause unless a jury, not the judge, found that her criminal conduct continued past November 1, 2004. Since the jury made no such finding, the court is bound to use the earlier guidelines.
DOJ-OGR-00010423.jpg
This legal document is a filing in the case of Ms. Maxwell, arguing that the 2003 U.S. Sentencing Guidelines should apply to her case, not the harsher 2004 Guidelines. The central dispute is the end date of the criminal conduct, with the defense contending it ceased by 2003 at the latest, before the 2004 Guidelines took effect. The document asserts that this factual determination must be made by a jury, not the court, consistent with the Ex Post Facto Clause.
DOJ-OGR-00010400.jpg
This document is a page from a legal filing, likely a response from the prosecution, arguing that the court's jury instructions were proper. It states the court correctly instructed the jury to consider only New York law as the predicate offense for the Mann Act counts and was right to reject the defendant's requests for additional limiting instructions regarding testimony about events in New Mexico and varying ages of consent. The filing asserts that the defendant's claim of potential jury confusion is speculative and implausible.
DOJ-OGR-00010313.jpg
This legal document, filed on behalf of Ms. Maxwell's defense by the Law Offices of Bobbi C. Sternheim, argues that Juror 50 was biased and should have been struck from the jury. The filing asserts that the juror's failure to disclose his history of sexual abuse, coupled with his incredible explanations for false statements on a questionnaire, demonstrates a bias that his own assurances of impartiality cannot overcome. The document cites legal precedents from the Second Circuit to support the claim that juror bias must be determined from circumstances, not the juror's self-serving statements.
DOJ-OGR-00010310.jpg
This is page 4 of a legal filing (Document 649) from the Law Offices of Bobbi C. Sternheim, filed on March 15, 2022, in the case of United States v. Maxwell. The text argues that 'Juror 50' demonstrated bias by lying on a questionnaire about his own history of sexual abuse, which the defense argues closely paralleled the abuse described by victims at the trial. The filing highlights that the juror was abused by a familiar person (his stepbrother), mirroring the allegations against Epstein and Maxwell, and argues he would have been struck for cause had he been honest.
DOJ-OGR-00010309.jpg
This legal document, filed on March 15, 2022, analyzes whether a juror, identified as Juror 50, gave false answers during jury selection (voir dire). Juror 50 answered "No" to a question about whether any family member had been accused of sexual abuse, but later admitted his stepbrother had been, and that his mother had reported it to the police. The court is now considering if this false statement satisfies the legal standard (the McDonough test) and would have provided Ms. Maxwell, a party in the case, with a valid reason to have the juror removed for cause.
DOJ-OGR-00010284.jpg
This legal document argues that the government's charges related to sex trafficking constitute a single, decade-long conspiracy rather than separate offenses. The author points to the similarity in conduct between victims Carolyn (2000s) and Jane (1990s), the overlap of participants like Sarah Kellen, and the consistent location of the Palm Beach residence to support the claim of a single scheme involving Epstein and Ms. Maxwell. The document contends that the government only separated the charges due to a legal technicality regarding the enactment date of a sex trafficking statute.
DOJ-OGR-00010283.jpg
This document is page 17 of a legal filing (likely a defense motion) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), arguing that certain counts in the indictment are multiplicitous. It details how the government incorporated the allegations of a witness named Carolyn (covering 2001-2004) into existing Mann Act conspiracies dating back to 1994, alongside victims Jane and Annie. The text highlights that Maxwell allegedly invited Carolyn to travel from Florida with Epstein.
DOJ-OGR-00010281.jpg
This legal document, part of a court filing, argues that the government's consistent theory during trial was that Ms. Maxwell and Epstein engaged in a single, overarching criminal conspiracy, not multiple separate ones. The filing cites the government's own arguments to the jury, which emphasized a 'common playbook' used against four accusers, to contend that the government's current position is a contradictory, 'after-the-fact attempt' to preserve convictions.
| 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 |
Denial of request
Judge Nathan denied Ms. Maxwell's request to share information with Judge Preska.
Request for permission to share information
Ms. Maxwell asked Judge Nathan for permission to share information under seal with Judge Preska.
Request to stay unseal proceedings
Ms. Maxwell asked Judge Preska to stay the unseal proceedings to allow her to get permission to share confidential information from a criminal case.
Something that happened between her move from a large apa...
The document references prior conversations between the witness (Rodgers) and Ms. Maxwell, which are the basis for a question from the attorney.
Detention conditions
Ms. Maxwell filed written complaints through internal prison procedures to her unit counselor, the warden, and the regional office to seek remediation for her conditions, but to no avail.
Discovery relevant to motions
Ms. Maxwell asked the government for documents relevant to these motions, but was denied.
Location tracking
Government located Maxwell by tracking her primary phone.
Something that happened between her move from a large apa...
The document references prior conversations between the witness (Rodgers) and Ms. Maxwell, which are the basis for a question from the attorney.
Video conference
Session reduced by 90 minutes; severe audio/video technical issues impacting confidentiality and visibility.
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.
Needs/requests
Communication via beeper if she needed something
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.
Discovery Disc
Federal Express envelope containing an unreadable discovery disc, delayed by two weeks.
Legal Emails
Legal emails prematurely deleted by MDC in violation of policy.
In-person legal conference
Four-hour legal conference marked by restrictions on water, earbuds, and privacy.
Upcoming flight on one of Mr. Epstein's planes
Ms. Maxwell would contact the witness via beeper to provide information about an upcoming flight.
Video conference
Monitor repositioned further away, impacting document review.
Household duties
Ms. Maxwell gave the witness, Juan, many instructions on how to perform his duties, including cleaning the house, serving, managing the kitchen, preparing shopping lists, and maintaining cleanliness.
Upcoming flight information
Ms. Maxwell would contact the witness (Rodgers) via beeper to convey information about upcoming flights on Mr. Epstein's planes.
Upcoming flight information
After beepers were no longer used, Ms. Maxwell would contact the witness (Rodgers) via cell phone to convey information about upcoming flights on Mr. Epstein's planes.
General communication
Communication via cell phones
CorrLinks emails
Ms. Maxwell's CorrLinks emails were allegedly erased by guards.
Non-legal personal matters
Her non-legal phone calls are monitored in real time, and information from them was used by staff to confront her about a personal matter (the death of someone close to her).
Legal consultation
Guards are described as feverishly writing while observing Ms. Maxwell during videoconferencing with her counsel.
Denial of stay
Judge Preska denied Ms. Maxwell's request for a stay, stating there was no factual basis.
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