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 | Alleged mistreatment | Guards allegedly harmed Ms. Maxwell by failing to provide adequate food, damaging her discovery h... | MDC | View |
| N/A | Pretrial detention | Ms. Maxwell's pretrial detention, during which she experienced conditions described as difficult ... | MDC | View |
| N/A | Filing of grievances | Ms. Maxwell filed hundreds of administrative forms (BP-8s, BP-9s, and BP-10s) to advocate for her... | MDC | View |
| N/A | Arrest | FBI agents arrived at Ms. Maxwell's house. The security guard mistook them for the press and aler... | the house | View |
| N/A | Legal proceeding | An initial bail hearing where the reason for Ms. Maxwell's cellphone being wrapped in tin foil wa... | Court | View |
| N/A | Confrontation | MDC staff (psychological services) confronted Ms. Maxwell about the death of someone close to her... | MDC | View |
| N/A | Legal proceeding | A legal argument for a new trial for Ms. Maxwell. | N/A | View |
| N/A | Refusal of travel | Carolyn testified that she refused offers from Epstein and Ms. Maxwell to travel with them to Eps... | Epstein's island | View |
| N/A | Legal proceeding | Jury instruction for Case 1:20-cr-00330-PAE, specifically Instruction No. 35, concerning the seco... | N/A | View |
| N/A | Legal motion | Ms. Maxwell filed a motion for a new trial based on Juror No. 50's failure to answer truthfully d... | N/A | View |
| N/A | Legal proceeding | A court hearing or filing regarding Ms. Maxwell's bail conditions and potential for detention. | N/A | View |
| N/A | Flight | Discussion of past flights to Interlochen that Ms. Maxwell may or may not have been a passenger on. | Interlochen | View |
| N/A | Legal proceeding | Discussion of the defendant's motion to sever perjury counts from Mann Act counts for trial. | N/A | View |
| N/A | Legal proceeding | A legal argument is being made for the questioning of Juror No. 50 to determine actual bias. | N/A | View |
| N/A | Arrest | Ms. Maxwell was arrested at some point prior to the events described in the document. | N/A | View |
| N/A | Trial | A trial where the legal instructions to the jury regarding Mann Act counts were discussed. | Court | View |
| N/A | Legal proceeding | An appeal that the document argues will become moot if review awaits a final judgment in a relate... | N/A | View |
| N/A | Legal proceeding | An unsealing process overseen by Judge Preska, for which Ms. Maxwell seeks to share information. | N/A | View |
| N/A | Move | Ms. Maxwell moved from a large apartment on 59th Street to a studio apartment. | Manhattan | View |
| N/A | Legal proceeding | Ms. Maxwell's trial, which resulted in a jury verdict that is now being challenged. | N/A | View |
| N/A | Legal proceeding | Unsealing of materials subject to a civil protective order in a case involving Ms. Maxwell. | N/A | View |
| N/A | Legal case | Giuffre v. Maxwell | this Court | View |
| N/A | Legal case | United States v. Maxwell | N/A | View |
| N/A | Legal proceeding | The government's motion to preclude the defense from eliciting evidence about its motives for pro... | N/A | View |
| N/A | Targeting of a person | The defendant worked with Epstein to identify and target a person named Jane. | N/A | View |
DOJ-OGR-00008491.jpg
This legal document, filed on December 17, 2021, is a jury instruction (No. 27) from a criminal case (1:20-cr-00330-PAE). It pertains to Count Six, 'Sex Trafficking of a Minor,' and directs the jury on the second element the Government must prove: that the defendant, Ms. Maxwell, knew that the victim, Carolyn, was under eighteen years of age.
DOJ-OGR-00008490.jpg
This document is page 34 of 82 from a court filing dated December 17, 2021, in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains Jury Instruction No. 26 regarding 'Count Six: Sex Trafficking of a Minor – First Element,' specifically instructing the jury on the requirement to prove that Maxwell knowingly recruited, enticed, harbored, transported, provided, or obtained a specific individual named Carolyn.
DOJ-OGR-00008486.jpg
This document is page 30 of 82 from a court filing filed on December 17, 2021, in Case 1:20-cr-00330-PAE. It contains Jury Instruction No. 22 regarding Count Four (Transportation of a Minor to Engage in Illegal Sexual Activity), specifically the 'Third Element,' which requires the Government to prove Ms. Maxwell knew the victim, 'Jane,' was under seventeen years old.
DOJ-OGR-00008485.jpg
This legal document is a jury instruction (Instruction No. 21) from a court case filed on December 17, 2021. It pertains to Count Four, the transportation of a minor named Jane by Ms. Maxwell for illegal sexual activity. The instruction clarifies that for a conviction, the government must prove that a 'significant or motivating purpose' of the interstate travel was for illegal sexual activity, not necessarily the 'sole purpose'.
DOJ-OGR-00008484.jpg
This document is page 28 of a court filing (Document 562) dated December 17, 2021, from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains Jury Instruction No. 20 regarding Count Four: Transportation of a Minor to Engage in Illegal Sexual Activity. The text defines the legal requirements for proving Ms. Maxwell knowingly transported the victim 'Jane' across state lines or internationally, noting that personal transportation is not required if she made the arrangements (e.g., buying tickets) and that the victim's consent is irrelevant.
DOJ-OGR-00008480.jpg
This document is a jury instruction from a legal case (1:20-cr-00330-PAE), filed on December 17, 2021. It details the third element of Count Two, 'Enticement to Engage in Illegal Sexual Activity,' specifically defining the legal standards for 'intent' and 'significant or motivating purpose' for the jury. The instruction clarifies that the prosecution (the Government) must prove beyond a reasonable doubt that a significant purpose of Ms. Maxwell encouraging 'Jane' to travel across state lines was for illegal sexual activity, and that this purpose was not merely incidental to the trip.
DOJ-OGR-00008478.jpg
This legal document, filed on December 17, 2021, is a jury instruction from a criminal case (Case 1:20-cr-00330-PAE). It details Instruction No. 15, which explains the first element the government must prove against the defendant, Ms. Maxwell, for Count Two: "Enticement to Engage in Illegal Sexual Activity." The document defines key legal terms for the jury, including "interstate commerce" and the standard for acting "knowingly."
DOJ-OGR-00008474.jpg
This legal document, filed on December 17, 2021, is a jury instruction (Instruction No. 11) from a criminal case. It directs the jury to consider each of the six counts against the defendant, Ms. Maxwell, separately and to only find her guilty if the Government has proven every element of a specific charge beyond a reasonable doubt.
DOJ-OGR-00008470.jpg
This document is page 14 of a court filing (Document 562) from Case 1:20-cr-00330-PAE, filed on December 17, 2021. It contains 'Instruction No. 8: Reasonable Doubt,' providing legal definitions and instructions to the jury regarding the burden of proof required to convict or acquit the defendant, explicitly named as Ms. Maxwell (Ghislaine Maxwell). The text outlines the standard of 'reasonable doubt' versus 'possible doubt' and instructs jurors on their duty based on their abiding belief of her guilt.
DOJ-OGR-00008469.jpg
This legal document is a jury instruction, specifically Instruction No. 7, from a criminal case (1:20-cr-00330-PAE) filed on December 17, 2021. It explains the legal principles of the presumption of innocence and the burden of proof, stating that the defendant, Ms. Maxwell, is presumed innocent and the Government has the sole responsibility to prove her guilt beyond a reasonable doubt. The instruction emphasizes that this burden never shifts to the defendant, even if she presents a defense.
DOJ-OGR-00008467.jpg
This legal document provides jury instructions regarding improper considerations. It instructs jurors to base their verdict solely on evidence and to avoid discrimination based on personal feelings or biases related to race, color, religion, national ancestry, sexual orientation, gender identity, gender, economic circumstances, or any other similar factor.
DOJ-OGR-00008434.jpg
This document is a legal letter filed on December 18, 2021, addressed to Judge Alison J. Nathan regarding the trial of Ghislaine Maxwell. The defense requests permission for a witness, Mr. Hamilton, to testify remotely from London via WebEx because he has tested positive for COVID-19 and cannot travel. The defense argues that precluding his testimony would violate Maxwell's constitutional rights to present a defense and confront accusers, specifically mentioning the need to expose the bias of an accuser named Kate.
DOJ-OGR-00008433.jpg
This document is page 3 of a legal filing (Case 1:20-cr-00330-PAE) dated December 15, 2021, addressed to Judge Alison J. Nathan. It presents defense arguments supporting the admissibility of testimony from a witness named Mr. Hamilton regarding statements made by 'Kate,' arguing that this evidence proves bias and is not a collateral matter. The text cites various legal precedents to refute the government's objections.
DOJ-OGR-00008426.jpg
This legal document, dated December 15, 2021, is an argument from Ms. Maxwell's counsel to Judge Alison J. Nathan regarding the trial testimony of a witness named 'Jane'. Counsel argues that because Jane denied the substance of a prior statement in court, they should be allowed to introduce extrinsic evidence to prove that statement under Federal Rule of Evidence 613, citing legal precedent. The document concludes by noting that due to time constraints, counsel was unable to meet a 10:15 p.m. deadline to list all such disputed statements.
DOJ-OGR-00008417.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on December 17, 2021. It features a legal argument between Ms. Menninger (defense) and the Court regarding hearsay rules. Menninger argues that testimony stating other accusers did *not* mention Ms. Maxwell is not hearsay (as it is an absence of a statement) and should be admissible if the government introduces evidence suggesting other victims exist without calling them to the stand.
DOJ-OGR-00008416.jpg
This document is a court transcript from December 17, 2021, detailing a legal argument about the admissibility of evidence in a sex trafficking case. The prosecution argues that the defense cannot introduce potentially exculpatory hearsay statements through law enforcement agents and must call the original witnesses. Defense counsel, Ms. Menninger, counters that the absence of an implicating statement is not hearsay, a point which the judge appears to challenge.
DOJ-OGR-00008415.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on December 17, 2021. It details a legal argument by defense attorney Ms. Menninger, who asserts that if the government introduces evidence (such as message pads) relating to individuals other than the four primary accusers, the defense should be allowed to introduce statements from those individuals claiming Ms. Maxwell was not involved. Prosecutor Ms. Moe agrees to defer the issue until trial, provided the defense does not mention it in their opening statement.
DOJ-OGR-00008413.jpg
This document is a court transcript from a hearing dated December 17, 2021, in the case against Ms. Maxwell. The prosecution, represented by Ms. Moe, is arguing that the defense should be precluded from introducing statements from other alleged victims unless they first formally proffer which witnesses they intend to call. The government contends this is necessary to prevent the introduction of inappropriate hearsay evidence during opening statements or cross-examination.
DOJ-OGR-00008411.jpg
This document is a page from a court transcript dated December 17, 2021, in which the judge is speaking. The judge outlines the rules for cross-examination, stating that the defense will be permitted to question law enforcement about the thoroughness of their investigation and to impeach government witnesses. The judge notes that denying these lines of questioning to the defense, represented by Ms. Maxwell, would have implications under the confrontation clause.
DOJ-OGR-00008409.jpg
This legal document, filed on December 17, 2021, is a page from a court proceeding in the case against Ms. Maxwell. The judge is providing guidance on the admissibility of evidence, citing the 2013 case 'United States v. Borrero' as precedent. The court will permit the defense to cross-examine government witnesses about their prior statements that did not implicate Ms. Maxwell in order to impeach their credibility.
DOJ-OGR-00008408.jpg
This document is a page from a legal transcript or filing, dated December 17, 2021, arguing against the admissibility of a prior 2008 decision not to indict Ms. Maxwell. The speaker contends that the reasons for the 2008 decision by officials in the Southern District of Florida are not relevant to the current case, would be prejudicial, and could cause juror confusion. This is contrasted with the 'White' case, where a prior charging decision was deemed admissible because it directly related to a witness's credibility.
DOJ-OGR-00008407.jpg
This document is a page from a court transcript, likely a judge's ruling, dated December 17, 2021. The speaker explains why a Non-Prosecution Agreement (NPA) is not being admitted as evidence, citing risks of prejudice, juror confusion, and undue delay that outweigh its relevance. The speaker also provides guidance that the government's prior charging decisions regarding Ms. Maxwell and Jeffrey Epstein are likely inadmissible.
DOJ-OGR-00008404.jpg
This legal document, part of a court filing from December 17, 2021, details a court's reasoning for excluding certain evidence from a trial involving Ms. Maxwell. The court argues that evidence proposed by the defense concerning the government's motives for the investigation—including a Miami Herald article and statements from Attorney General William Barr—would confuse and delay the trial, with its prejudicial effect outweighing its probative value. The document suggests the defense should focus on the credibility of witnesses and the sufficiency of the evidence presented at trial instead.
DOJ-OGR-00008398.jpg
This legal document, part of a court filing dated December 17, 2021, outlines the legal principles guiding the court's analysis of the government's investigation into Ms. Maxwell. It references precedents from the Second Circuit and the Supreme Court to establish rules regarding investigative techniques, challenges to government motives, and the admissibility of evidence related to charging decisions.
DOJ-OGR-00008391.jpg
This legal document is a page from a court filing, specifically page 5 of 6 from Document 548 in case 1:20-cr-00330-PAE, filed on December 15, 2021. The Court denies the Defense's request for a witness to testify under a pseudonym, arguing that the witness does not qualify as a victim under the Crime Victims' Rights Act because her anticipated testimony is that she was not a target of sexual misconduct by Epstein or Ms. Maxwell. The Court distinguishes this situation from a prior ruling where pseudonyms were allowed to protect the identities of other, actual victims.
| 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 Defense
Facilitated on-going communication.
Phone Message
Telephoned. (No specific message text written)
Status/Indictment
Maxwell stayed in contact with the government, allegedly to stave off indictment, but did not provide whereabouts.
Pretrial motions
Request for a legal call to confer with counsel regarding pretrial motions was denied.
Defense Preparation
Reference to Maxwell's need to communicate freely with counsel to prepare for defense.
Discovery in Giuffre v. Maxwell
Two depositions designated confidential.
Sniper threat
A high-ranking prison guard told Ms. Maxwell that there was concern she would be shot by a sniper.
A booklet/checklist
Mr. Alessi recalls telling Ms. Maxwell that he would not confirm or do the work required by a booklet/checklist because it was too much work on top of his daily duties.
Travel arrangement for Jane
The document mentions an incident where 'allegedly Ms. Maxwell got on the phone and somehow arranged for Jane to get back to Palm Beach'.
Legal Defense
Meetings behind closed doors, visible but not audible to staff.
Legal and non-legal mail
Delivery of her mail was significantly delayed.
Sniper threat
A high-ranking prison guard told Ms. Maxwell that there was concern she would be shot by a sniper.
CorrLinks emails
Receipt of CorrLinks emails was significantly delayed and the emails were prematurely deleted by the MDC.
Rules and Regulations
Guards were the sole source of information; Maxwell was instructed not to speak to them lest she face disciplinary sanction.
Legal and non-legal mail
Delivery of her mail was significantly delayed.
Legal Emails
MDC allegedly prematurely deleted legal emails.
Civil Deposition
Testimony where the judge concluded dishonesty/perjury occurred.
Ms. Maxwell's assets
An interview conducted after Ms. Maxwell's arrest where she reported her assets from memory, stating she believed she had approximately $3.8 million in assets.
Withdrawal of HMF
Mr. Markus informed HMF that he discussed HMF's withdrawal with Ms. Maxwell, and she consents to it.
Divorce
Discussed divorce to create distance and protect him from consequences of association.
CorrLinks emails
Receipt of CorrLinks emails was significantly delayed and the emails were prematurely deleted by the MDC.
Discovery Disc
Federal Express envelope containing an unreadable discovery disc.
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.
Missed Call
Telephoned / Please Call
Needs/requests
Communication via beeper if she needed something
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