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 | Legal proceeding | A potential criminal trial for Ms. Maxwell where the joinder of Perjury Counts is being debated. | N/A | View |
| N/A | Legal proceeding | Proposal of conditions for Ms. Maxwell's pretrial release. | New York City | View |
| N/A | Legal proceeding | Ms. Maxwell's motion regarding Juror No. 50's conduct, leading to a discussion about an evidentia... | N/A | View |
| N/A | Deposition | Ms. Maxwell gave a deposition stating she lived at Kinnerton beginning in '92 or '93. | N/A | View |
| N/A | Aircraft ownership | Ms. Maxwell had an option on a quarter share or quarter ownership of a private jet. | N/A | View |
| N/A | Travel | Ms. Maxwell flew on private planes and also commercial airlines. | N/A | View |
| N/A | Trip | The witness, Carolyn, engaged in a "sexualized massage" with Jeffrey Epstein and was subsequently... | N/A | View |
| N/A | Bail application | The letter discusses the intent to file a 'renewed bail application for Ms. Maxwell'. | N/A | View |
| N/A | Employment | Ms. Maxwell worked as manager of Epstein's properties. | N/A | View |
| N/A | Legal request | Ms. Maxwell requested Judge Preska to reevaluate her unsealing order. | N/A | View |
| N/A | Legal proceeding | Jury instruction regarding the third element of Count Four of an Indictment, specifically the cha... | N/A | View |
| N/A | Interview | Ms. Maxwell was interviewed by Pretrial Services to estimate her assets. | jail cell | View |
| N/A | Legal proceeding | Pre-trial motion regarding the admissibility of evidence for Ms. Maxwell's defense. | Court | View |
| N/A | Cooperation with investigation | Carolyn cooperated with the government and is testifying against Ms. Maxwell. | N/A | View |
| N/A | Law enforcement action | The arrest of Ms. Maxwell, the circumstances of which are said to 'cast some doubt on the claim t... | N/A | View |
| N/A | Legal proceeding | The indictment of Ms. Maxwell. The court questions her understanding of the seriousness of the ch... | N/A | View |
| N/A | Legal proceeding | Ms. Maxwell gave two depositions in the defamation case where she allegedly lied, leading to Coun... | N/A | View |
| N/A | Legal proceeding | Ms. Maxwell seeks an order to share information with Judge Preska for a decision on unsealing dep... | N/A | View |
| N/A | Legal proceeding | An alternative argument is made for the Court to exercise mandamus jurisdiction to direct the dis... | N/A | View |
| N/A | Alleged crime | Group sexualized massages in which Ms. Maxwell was allegedly involved, according to testimony fro... | N/A | View |
| N/A | Alleged crime | A topless massage allegedly performed by Ms. Maxwell on Annie, during which she rubbed Annie's ch... | N/A | View |
| N/A | Alleged crime | An incident where Ms. Maxwell allegedly groped Carolyn's breasts and commented on her hips, accor... | N/A | View |
| N/A | Legal proceeding | Pretrial detention of Ms. Maxwell, which the document argues has become unconstitutional punishment. | N/A | View |
| N/A | Legal proceeding | A future trial where the government will seek a life sentence for Ms. Maxwell. | N/A | View |
| N/A | Deposition | Ms. Maxwell gave deposition testimony where she denied ownership of or responsibility for Deposit... | N/A | View |
DOJ-OGR-00008389.jpg
This legal document, filed on December 15, 2021, is a court filing arguing against the Defense's request for witness anonymity for Ms. Maxwell's trial. The filing contends that the Defense's concerns about publicity are common in high-profile cases and do not meet the standard for granting pseudonyms, unlike the alleged victims who have a statutory right to privacy. It heavily cites the precedent of *United States v. Rainiere*, where a similar request for anonymity for supporters was denied because the public's interest in access prevailed over privacy concerns for matters not traditionally considered private.
DOJ-OGR-00008377.jpg
This legal document, filed on December 15, 2021, is a motion from the prosecution arguing against allowing testimony from an individual named Scarola. The prosecution contends that Scarola's proposed testimony regarding another witness, Carolyn, is irrelevant and non-impeaching, as the information has already been obtained from Carolyn directly. The document also details over $3.2 million in compensation Carolyn received from claims related to Epstein and Sarah Kellen, and discusses a 2020 meeting where Scarola showed Carolyn a picture of an Epstein associate.
DOJ-OGR-00008372.jpg
This document is the final page of a legal filing (Document 544) from December 13, 2021, addressed to Judge Alison J. Nathan. Attorneys for Ghislaine Maxwell assert her constitutional right to call Mr. Scarola, Mr. Edwards, and Mr. Glassman as witnesses. The page includes the contact information for her legal counsel from three different law firms.
DOJ-OGR-00008371.jpg
This legal document, part of a court filing, argues that certain communications related to a claimant named 'Jane' are not protected by attorney-client privilege. The argument is based on her representative, Mr. Glassman, sharing her statements and settlement demands with third parties, including the government, the EVCP, and Ms. Maxwell's counsel. The document details specific financial demands, such as a $25 million demand and a $5 million offer, to demonstrate that these communications were not confidential.
DOJ-OGR-00008370.jpg
This legal document, dated December 13, 2021, argues that testimony from attorney Robert Glassman is not protected by attorney-client privilege. It focuses on a discrepancy in a witness's ('Jane') memory, where she claimed Mr. Epstein took her to see 'The Lion King' on Broadway in 1994, three years before it premiered. The document details communications between AUSA Rossmiller and Mr. Glassman where the government pointed out the error, but Jane insisted her story was correct.
DOJ-OGR-00008369.jpg
This legal document, filed on December 14, 2021, argues for the questioning of attorney Brad Edwards regarding a U-Visa application he submitted for his client, Kate. The filing asserts that Kate denied seeking a U-Visa during cross-examination, making her attorney's actions relevant to her motive and bias as a witness. The document contends that this action is not protected by attorney-client privilege, or if it was, the privilege was waived.
DOJ-OGR-00008365.jpg
This legal document, dated December 13, 2021, is a filing on behalf of Ms. Maxwell addressed to Judge Alison J. Nathan. The defense argues that the Court should permit the testimony of three witnesses—Mr. Scarola, Mr. Edwards, and Mr. Glassman—to establish motive and bias of Maxwell's accusers, after the government refused to stipulate. The document details the proposed testimony of attorney Jack Scarola, including his prior representation of an accuser named 'Carolyn' in a civil suit against Jeffrey Epstein and his communications with the government.
DOJ-OGR-00008343.jpg
This document is page 33 of a court transcript from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE) dated December 10, 2021. Defense attorney Mr. Everdell argues that testimony regarding Accuser 2 and Accuser 3 might lead the jury to convict Maxwell on an improper basis because their allegations do not relate to New York law violations. The Court acknowledges the need to clarify to the jury that while evidence may be relevant to enticement charges, sexual activity in New Mexico cannot be considered as the illegal conduct charged in the indictment itself.
DOJ-OGR-00008309.jpg
This document is page 7 of a legal filing from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on December 9, 2021. It discusses the legal admissibility of a telephone directory (Exhibit GX 606) found at the Palm Beach residence, arguing it is not hearsay because it is offered to prove a link between Maxwell and the listed contacts rather than the truth of the contact details. The text cites witness Mr. Alessi's testimony confirming Maxwell regularly used this directory.
DOJ-OGR-00008307.jpg
This document is page 5 of a court filing (Case 1:20-cr-00330-PAE) dated December 9, 2021, regarding the Ghislaine Maxwell trial. The text discusses the legal admissibility of Government Exhibit 52 (GX 52), identified as a household directory from the Palm Beach property. The court argues that witness Mr. Alessi sufficiently authenticated the book based on his familiarity with it, despite Defense objections regarding the chain of custody and physical alterations (Post-it notes, pencil markings).
DOJ-OGR-00008305.jpg
This legal document, filed on December 9, 2021, details the testimony of a witness, Mr. Alessi, regarding telephone directories belonging to Mr. Epstein and Ms. Maxwell. Mr. Alessi describes the directories' physical characteristics, their contents (including contacts for friends, family, business, and massage therapists in Palm Beach), and how they were regularly updated. His testimony, which confirms the directories' appearance and purpose, is presented as being corroborated by other evidence, such as a 'Household Manual' (Government Exhibit 606).
DOJ-OGR-00008275.jpg
This legal document is a court filing by the Government arguing for the admission of a contact book (Government Exhibit 52) as evidence. The argument relies on the testimony of Juan Alessi, a former employee of Epstein, who identified the book as being from Epstein's Palm Beach house. Alessi confirmed the book's appearance and recognized names within it, establishing its authenticity and relevance to the case.
DOJ-OGR-00008270.jpg
This legal document is a filing arguing against the government's attempt to admit 'Exhibit 52' as evidence in a trial involving Ms. Maxwell. The author contends that the government has failed to authenticate the exhibit, has abandoned its original premise that it was Ms. Maxwell's book, and that admitting it at this late stage would be unfair. The argument is bolstered by the government's decision not to call a key witness, 'Employee-1', who was supposed to link the exhibit to Ms. Maxwell.
DOJ-OGR-00008269.jpg
This document is a page from a court transcript dated December 8, 2021, in a case before The Honorable Alison J. Nathan. The testimony features Ms. Maxwell being questioned about a document, which she denies creating, knowing the author of, or having on her computer. She specifically denies providing information for a section titled 'Massage Florida' and refutes the characterization that she 'brought' a woman to 'Jeffrey' who was subsequently hired.
DOJ-OGR-00008268.jpg
This legal document, dated December 8, 2021, is page 4 of a filing addressed to The Honorable Alison J. Nathan. It argues that testimony from Ms. Maxwell is insufficient to authenticate Deposition Exhibit 13 and Exhibit 52 for admission as evidence. The document quotes Ms. Maxwell's April 2016 testimony where she denies knowledge of the document's creation and states it was not her job to keep track of Jeffrey Epstein's contact information.
DOJ-OGR-00008267.jpg
This legal document is a filing on behalf of Ms. Maxwell arguing against the government's attempt to use her April 2016 deposition testimony. The core argument is that "Deposition Exhibit 13" is an unauthenticated photocopy and is fundamentally different from "Exhibit 52." This claim is supported by testimony from Mr. Alessi, who noted a significant physical discrepancy between Exhibit 52 and books he saw while employed by Mr. Epstein.
DOJ-OGR-00008266.jpg
This legal document, dated December 8, 2021, is an argument addressed to Judge Alison J. Nathan on behalf of Ms. Maxwell. The argument contends that the government cannot admit a piece of evidence, referred to as Exhibit 52, because it cannot be properly authenticated as a business record under the Federal Rules of Evidence. The filing asserts that Ms. Maxwell disclaimed all knowledge of a related document (Exhibit 13) during a deposition, and therefore the government fails to meet the legal requirements for its admission.
DOJ-OGR-00008240.jpg
This document is page 4 of a court filing from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on December 6, 2021. It details a judicial rejection of defense arguments that a witness named 'Jane' waived attorney-client privilege by cooperating with the government. The court rules that essential information regarding credibility does not automatically void privilege, citing Rule 403 and previous transcripts.
DOJ-OGR-00008231.jpg
This legal filing from December 5, 2021, addressed to Judge Alison J. Nathan, argues for the exclusion of specific evidence in the case against Ghislaine Maxwell. The defense contends that 2019 photographs of Jeffrey Epstein's house are irrelevant and prejudicial because items like massage tables and artwork are 'highly mobile' and may not reflect the conditions present when the accuser, Jane, was there in 1994-1996. The document asserts that the photos are inflammatory and lack connection to Ms. Maxwell.
DOJ-OGR-00008230.jpg
This legal document, part of a letter to Judge Alison J. Nathan dated December 5, 2021, presents an argument criticizing the government's handling of photographic evidence. The author contends that the government failed to properly authenticate 2019 photos as representative of a scene from 1994-1996 by not showing them to a witness named Jane during her testimony. The document dismisses the government's rationale that doing so would have diminished the photos' value as independent corroboration, suggesting the real reason was a fear that Jane's response would not support their case.
DOJ-OGR-00008226.jpg
This legal document, dated December 5, 2021, is a filing to Judge Alison J. Nathan arguing against the admissibility of interior photographs of Mr. Epstein's apartment. The author contends the photos, taken in 2019, cannot be proven to accurately represent the apartment's state during the charged conspiracy, which ended in 2004. The document highlights that the government's case for the photos' relevance relies solely on the testimony of a witness, "Jane," who described the apartment's interior based on her memory from an alleged visit in the mid-1990s.
DOJ-OGR-00008224.jpg
This legal document, filed on December 5, 2021, is a request from the U.S. Government to the Court in case 1:20-cr-00330-PAE. The Government proposes a specific limiting instruction for the jury to be read before a witness, identified as "Witness-3," testifies. The instruction aims to prevent prejudice by clarifying that any testimony about sexual conduct between Witness-3 and Mr. Epstein is not part of the charged crimes and cannot be used to judge the character or propensity of either Mr. Epstein or Ms. Maxwell.
DOJ-OGR-00008209.jpg
This legal document, dated December 3, 2021, is a filing addressed to Judge Alison J. Nathan. The author argues that Ms. Maxwell has a constitutional right to call Mr. Glassman as a witness to question him about advice he gave to a person named Jane regarding cooperation with the government. The argument posits that any attorney-client privilege was waived when Mr. Glassman disclosed this advice, and that this testimony is crucial for Ms. Maxwell's defense.
DOJ-OGR-00008207.jpg
This legal document is page 2 of a filing to Judge Alison J. Nathan, dated December 3, 2021. The author argues that the government cannot use attorney-client privilege to prevent Ms. Maxwell's team from cross-examining a witness named Jane about a statement her attorney, Mr. Glassman, made to her. The filing contends the privilege does not apply because the communication was not intended to be confidential and, in any case, was waived when it was relayed to the government.
DOJ-OGR-00001923.jpg
This document is a page from a court transcript dated December 10, 2020. An attorney argues during a bail hearing, dismissing the government's evidence concerning a threat from a 'Ms. Moe' as irrelevant 'spin' not connected to their client, 'Ms. Maxwell'. The attorney then pivots to the legal standard for pretrial release, quoting statute 3142 to argue for release under the least restrictive conditions.
| 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 |
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).
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.
CorrLinks emails
Ms. Maxwell's CorrLinks emails were allegedly erased by guards.
Upcoming flight on one of Mr. Epstein's planes
Ms. Maxwell would contact the witness via beeper to provide information about an upcoming flight.
Legal Emails
Legal emails prematurely deleted by MDC in violation of policy.
Missed Call
Telephoned / Please Call
Discovery Disc
Federal Express envelope containing an unreadable discovery disc.
Upcoming flight information
Ms. Maxwell would contact the witness (Rodgers) via beeper to convey information about upcoming flights on Mr. Epstein's planes.
Status/Indictment
Maxwell stayed in contact with the government, allegedly to stave off indictment, but did not provide whereabouts.
Video conference
Session reduced by 90 minutes; severe audio/video technical issues impacting confidentiality and visibility.
Legal Defense
Meetings behind closed doors, visible but not audible to staff.
Discovery Disc
Federal Express envelope containing an unreadable discovery disc, delayed by two weeks.
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.
Phone Message
Telephoned. (No specific message text written)
Needs/requests
Communication via beeper if she needed something
General communication
Communication via cell phones
Pretrial motions
Request for a legal call to confer with counsel regarding pretrial motions was denied.
Location tracking
Government located Maxwell by tracking her primary phone.
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.
Discovery relevant to motions
Ms. Maxwell asked the government for documents relevant to these motions, but was denied.
In-person legal conference
Four-hour legal conference marked by restrictions on water, earbuds, and privacy.
Video conference
Monitor repositioned further away, impacting document review.
Legal consultation
Guards are described as feverishly writing while observing Ms. Maxwell during videoconferencing with her counsel.
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