Accuser-2

Person
Mentions
25
Relationships
6
Events
5
Documents
12

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Event Timeline

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6 total relationships
Connected Entity Relationship Type
Strength (mentions)
Documents Actions
person Minor Victim-2
Alias
5
1
View
person Accuser-1
Co victims alleged
5
1
View
person Jeffrey Epstein
Accuser alleged victim
1
1
View
person GHISLAINE MAXWELL
Adversarial alleged victim
1
1
View
person Jeffrey Epstein
Alleged victim abuser
1
1
View
organization BSF
Client
1
1
View
Date Event Type Description Location Actions
N/A Trip Alleged conspiracy to cause individuals (Accuser-1, Accuser-2, or anyone else) to travel for unla... N/A View
N/A Alleged criminal conduct Alleged "sexual abuse" of Accuser-2 and Accuser-3 by Epstein, in which the government alleges Ms.... N/A View
N/A N/A Accuser-2 read from her diary on a NY Times podcast. Podcast View
1996-01-01 N/A Period covered by Accuser-2's journal describing interactions with Jeffrey Epstein. New York View
1994-01-01 N/A Alleged conspiracy and overt acts violating the Mann Act involving Maxwell, Epstein, and three ac... New York, Florida, New Mexi... View

EFTA00029844.pdf

Defense counsel Laura Menninger objects to government redactions in the case US v. Maxwell. Menninger argues that 'Accuser-2's' diary entries are not confidential as they were shared on a NY Times podcast and do not implicate Maxwell. The letter also argues against redacting information about another accuser (name redacted) who has publicized her allegations via Netflix and podcasts, referencing the 'Kramer notes', and discusses sealing issues related to Maxwell's deposition in a separate civil case ruled on by Judge Preska.

Legal correspondence / motion response
2025-12-25

EFTA00028880.pdf

This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on March 15, 2021, supporting her motion to dismiss the indictment based on the Non-Prosecution Agreement (NPA) Jeffrey Epstein signed in Florida. Maxwell argues that the NPA's clause immunizing 'potential co-conspirators of Epstein' explicitly covers her and bars the current prosecution in the Southern District of New York. The defense contends that the government's attempt to limit the NPA geographically (to Florida) or to specific crimes is contradicted by the plain text of the agreement and legal precedent regarding plea agreements.

Legal reply memorandum (united states district court, southern district of new york)
2025-12-25

EFTA00014671.pdf

This document is a letter from Ghislaine Maxwell's defense counsel to Judge Alison Nathan, dated May 12, 2021, arguing for the enforcement of a subpoena for evidence controlled by the law firm Boies, Schiller, and Flexner (BSF). The defense seeks the full production of a journal kept by 'Accuser-2' in 1996, arguing that the government is relying on selective excerpts to support its case while ignoring potentially exculpatory context in the rest of the journal. The letter also addresses disputes over the production of a pair of boots and original photographs, accusing the government of interfering with the defense's investigation and practicing 'selective ignorance.'

Legal correspondence (defense letter to court)
2025-12-25

DOJ-OGR-00002357(2).jpg

This legal document, filed on February 4, 2021, discusses a July 2016 deposition of Maxwell. It states that a superseding indictment alleges Maxwell committed perjury during this deposition by providing false testimony about her knowledge of sexual activities at Epstein's Palm Beach house. The document notes that a district court had previously compelled her testimony over privacy objections, believing a protective order was sufficient.

Legal document
2025-11-20

DOJ-OGR-00002284.jpg

This document is page 6 of a legal filing (Document 120) dated January 25, 2021, from the case U.S. v. Ghislaine Maxwell. It outlines the 'Mann Act Counts' (Counts One through Four) of the indictment, detailing allegations that Maxwell conspired with Jeffrey Epstein between 1994 and 1997 to transport individuals for illegal sexual activity in New York, Florida, New Mexico, and London. It specifically notes the involvement of three accusers (Accuser-1, -2, and -3) and argues for the severance of Counts Five and Six to avoid juror confusion.

Legal filing / court motion
2025-11-20

DOJ-OGR-00002680.jpg

This document is a preliminary statement from a legal motion filed on behalf of Ghislaine Maxwell on February 4, 2021. The defense requests that the Court strike allegations related to 'Accuser-3' from the indictment, arguing that the alleged conduct occurred in England where Accuser-3 was above the age of consent and did not involve travel. The motion claims the government is improperly using these allegations to bolster its case regarding Mann Act violations involving 'Accuser-1' and Jeffrey Epstein.

Legal document
2025-11-20

DOJ-OGR-00002705.jpg

This document is a legal filing from a court case dated February 4, 2021. The defense argues that the contents of a specific interview constitute exculpatory 'Brady material' and asks the Court to compel the government to produce any notes or reports from it, which are currently missing from discovery. The defense also notes its requests for the government to provide unredacted copies of two specific FBI reports that were part of the Miami FBI's investigation.

Legal document
2025-11-20

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.

Legal document
2025-11-20

DOJ-OGR-00002686.jpg

This document is page 11 of a legal filing (Document 146) from the Ghislaine Maxwell case, dated February 4, 2021. The defense argues that allegations regarding 'Accuser-3' are time-barred because the statute of limitations expired before the 2003 amendment to 18 U.S.C. ยง 3283, and retroactive application would violate the Ex Post Facto Clause. Furthermore, the defense contends that allegations involving Accuser-3 are irrelevant to the conspiracy charges, which should only pertain to Accuser-1 and Accuser-2.

Court filing (legal brief/motion)
2025-11-20

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.

Legal filing (motion/memorandum of law)
2025-11-20

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.

Legal document
2025-11-20

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.

Legal document
2025-11-20
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Investigation

From: Accuser-2
To: FBI

FBI interviewed Accuser-2 in 2006 regarding claims involving Ms. Maxwell.

Interview
2006-01-01

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