defendant
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
organization
GOVERNMENT
|
Legal representative |
13
Very Strong
|
62 | |
|
organization
The Court
|
Legal representative |
12
Very Strong
|
8 | |
|
person
Defense counsel
|
Legal representative |
11
Very Strong
|
21 | |
|
person
Juror 50
|
Legal representative |
11
Very Strong
|
17 | |
|
person
Epstein
|
Co conspirators |
11
Very Strong
|
11 | |
|
person
Spouse
|
Financial |
10
Very Strong
|
7 | |
|
person
JANE
|
Perpetrator victim |
10
Very Strong
|
5 | |
|
person
Defense counsel
|
Client |
10
Very Strong
|
10 | |
|
organization
The government
|
Legal representative |
10
Very Strong
|
18 | |
|
location
court
|
Legal representative |
10
Very Strong
|
16 | |
|
organization
GOVERNMENT
|
Adversarial |
10
Very Strong
|
24 | |
|
person
Defense counsel
|
Professional |
10
Very Strong
|
11 | |
|
person
Epstein
|
Business associate |
10
Very Strong
|
8 | |
|
person
Jeffrey Epstein
|
Business associate |
9
Strong
|
5 | |
|
person
ALISON J. NATHAN
|
Judicial |
9
Strong
|
5 | |
|
person
defendant's spouse
|
Marital |
8
Strong
|
4 | |
|
person
JANE
|
Alleged perpetrator victim |
8
Strong
|
3 | |
|
person
Jane
|
Business associate |
8
Strong
|
2 | |
|
person
Defendant's Spouse
|
Friend |
8
Strong
|
3 | |
|
person
Kate
|
Legal representative |
8
Strong
|
3 | |
|
person
Epstein
|
Co conspirator |
8
Strong
|
4 | |
|
person
CAROLYN
|
Criminal |
8
Strong
|
4 | |
|
person
Epstein
|
Association |
8
Strong
|
3 | |
|
person
Epstein
|
Professional |
8
Strong
|
4 | |
|
person
Bureau of Prisons
|
Custodial |
7
|
3 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Negotiations of the Non-Prosecution Agreement (NPA) between the defendant and prosecutors. | N/A | View |
| N/A | N/A | Discussion of legal arguments regarding sentencing enhancements (4B1.5(b) and 3B1.1(a)) for a def... | N/A | View |
| N/A | N/A | Discussion of the Department of Justice's practice of limiting plea agreements to specific USAOs ... | N/A | View |
| N/A | N/A | Argument that defendants should be able to rely on government promises in written agreements and ... | N/A | View |
| N/A | N/A | Grooming and abuse | Unspecified | View |
| N/A | N/A | Signing of affidavit by defendant. | MCC or Open Court | View |
| N/A | N/A | Affidavit signing/notarization for defendant. | MCC or Open Court | View |
| N/A | N/A | Pickpocketing incident where a defendant fled with a wallet containing $14. | Unknown | View |
| N/A | N/A | Sentencing of the defendant to 2-6 years in prison. | Court | View |
| N/A | N/A | Negotiation and execution of a plea agreement | Eleventh Circuit | View |
| N/A | N/A | Sentencing hearing ruling where judge overrules objection regarding 'continuing danger to the pub... | Courtroom | View |
| N/A | N/A | Flight to New Mexico | New Mexico | View |
| N/A | N/A | Resolution of the Defendant's motion or a hearing. | Court | View |
| N/A | N/A | Filing of Florida Defamation Action (Case No. CACE 15-000072). | Broward County Circuit Court | View |
| N/A | N/A | Indictment by Grand Jury | Unspecified | View |
| N/A | N/A | Judicial ruling on sentencing enhancement objection. | Courtroom | View |
| N/A | N/A | Defendant made Rule 29 application at the close of the Government's case. | Trial Court | View |
| N/A | N/A | Defendant enticed and transported Jane to New York. | New York | View |
| N/A | N/A | Attorney Visits | MDC Attorney Visiting Room | View |
| N/A | N/A | Florida Defamation Action | Florida | View |
| N/A | N/A | Issuance of Subpoena to Jane Doe No. 3 | Unspecified | View |
| N/A | N/A | Virginia brought Carolyn to the residence; Defendant greeted them and instructed Virginia. | The residence | View |
| N/A | N/A | Sex trafficking scheme | Two states | View |
| N/A | N/A | Jury Instructions and Testimony | Courtroom | View |
| N/A | N/A | Recruitment of Virginia | Unknown (Roadside stop) | View |
EFTA00014649.pdf
A digital calendar entry for November 21, 2021, serving as a reminder for a legal filing deadline related to Government Exhibit 52 (GX 52) in a court case (likely US v. Maxwell). The entry quotes a court order requiring the Government to reply to a defense argument that a specific witness ('Employee-1') cannot authenticate the exhibit because a former employee (name redacted) allegedly removed the document from Epstein's property previously.
EFTA00011431.pdf
A page from a set of jury instructions (marked with Bates stamp EFTA00011431) regarding 'Uncalled Witnesses.' The document instructs jurors not to draw inferences from the absence of witnesses mentioned during the trial who did not testify, noting that both sides had equal opportunity to call them. It further clarifies that the defendant in a criminal case has no burden to call witnesses or produce evidence.
DOJ-OGR-00000210.tif
This document excerpt details various legal agreements and plea agreements across different U.S. judicial districts, outlining the scope and binding nature of these agreements between defendants and specific United States Attorney offices or divisions of the Department of Justice. It emphasizes which entities are bound by each agreement and which are not. The document includes specific case citations with dates, defendants, and ECF numbers.
DOJ-OGR-00000206.tif
This document discusses the unequal bargaining power between the government and defendants in plea agreements, citing legal precedents and academic works. It highlights that ambiguities in such agreements should be construed against the government and emphasizes the significant power held by the United States Attorney in the legal process, making plea bargains akin to contracts of adhesion where the defendant has little choice but to accept the offer.
DOJ-OGR-00000203.tif
This document, likely a legal brief or argument, discusses the importance of the government upholding its promises in plea agreements. It argues that the NACDL urges the Court to ensure the government honors its commitments to defendants, especially given the significant rights defendants waive when entering such agreements. The text emphasizes that courts should enforce these promises to maintain fairness and trust in the legal system.
DOJ-OGR-00000103.tif
This document is a court judgment dated June 29, 2022, sentencing a defendant as per pages 2 through 8 of the judgment under the Sentencing Reform Act of 1984. It notes that counts 7 and 8 and underlying indictments were dismissed, and the defendant was found not guilty on count 2. The document also lists additional counts of conviction for transportation of a minor with intent to engage in criminal sexual activity (18 USC 2423.F, offense ended 12/31/1997, count 4) and sex trafficking of an individual under eighteen (18 USC 1591.F, offense ended 7/30/2004, count 6), and requires the defendant to notify the U.S. attorney of changes in personal information or economic circumstances until all financial obligations are paid.
DOJ-OGR-00018341.jpg
This document is a court transcript from August 10, 2022, in which a judge instructs a jury about an upcoming witness's testimony. The judge clarifies that because the witness was over the age of consent, her alleged sexual conduct with Mr. Epstein was not illegal under the indictment, and she is not considered a victim in this case. The jury is strictly forbidden from using this testimony to convict the defendant, Ms. Maxwell, or to infer anything about the character or criminal propensity of either Epstein or Maxwell.
DOJ-OGR-00018108.jpg
This document is a court transcript from August 10, 2022, detailing an argument by Ms. Comey to the Court. Ms. Comey asserts that a 'disturbing photograph' displayed outside Jeffrey Epstein's master bedroom contradicts the defense's claim that the defendant was unaware of Epstein's attraction to underage girls. The defense's argument, as described by Comey, relies on a 'halo effect' from Epstein's association with prominent people, which she argues the photograph directly refutes by serving as evidence of Epstein's lifestyle.
DOJ-OGR-00014781.jpg
This court transcript excerpt discusses the supervisory authority of Kellen, an employee, in relation to Maxwell, Epstein, and an unnamed defendant. It details arguments about whether Kellen's actions, such as making calls and scheduling massage appointments, constituted supervisory authority, and mentions testimony from pilots regarding Kellen's reporting structure. The discussion also touches upon a five-point enhancement for sex offenders.
DOJ-OGR-00014759.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 22, 2022, in which the judge overrules objections from the defendant (Ghislaine Maxwell). The court finds by a preponderance of evidence that the defendant personally recruited Virginia (Giuffre) while she was a minor to provide sexualized massages to Epstein, was aware of the sexual nature of these acts, and used monetary incentives to encourage Virginia to recruit another minor, Carolyn. The judge cites testimony from witnesses Annie, Jane, Kate, and Mr. Alessi, as well as flight records.
DOJ-OGR-00008662.jpg
This document is a jury instruction (Instruction No. 32) from a federal court case (1:20-cr-00330-PAE), filed on December 18, 2021. It outlines the four specific elements that the Government must prove beyond a reasonable doubt to convict a defendant of conspiracy to violate federal law, as charged in Counts One, Three, and Five of the indictment. The elements include the existence of an agreement, the defendant's knowing participation, the commission of an overt act by a member, and that the act was in furtherance of the conspiracy.
DOJ-OGR-00008653.jpg
This legal document is a jury instruction (Instruction No. 25) from case 1:20-cr-00330-PAE, filed on December 18, 2021. It outlines the four specific elements the Government must prove beyond a reasonable doubt to convict the Defendant on Count Six, Sex Trafficking of an Individual Under the Age of 18. The instruction specifies that this particular count pertains to a person named Carolyn and the alleged acts occurred between 2001 and 2004.
DOJ-OGR-00008651.jpg
This legal document is a jury instruction (Instruction No. 23) from Case 1:20-cr-00330-PAE, filed on December 18, 2021. It specifies that for Counts Two (enticement) and Four (transportation across state lines), the prosecution does not need to prove that the intended sexual activity actually occurred. The crucial element for the jury to consider is whether the Defendant possessed the required criminal intent at the time of the alleged acts.
DOJ-OGR-00008641.jpg
This document is page 103 of a court filing (Document 563) filed on December 18, 2021, containing Jury Instruction No. 14 for Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It outlines the three legal elements required to prove the Defendant guilty of 'Count Two: Enticement to Engage in Illegal Sexual Activity,' specifically noting that this count relates solely to an individual named 'Jane' between 1994 and 1997.
DOJ-OGR-00008639.jpg
This document is page 101 of the jury instructions filed on December 18, 2021, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The text, labeled Instruction No. 12, defines the legal distinction between 'Conspiracy Counts' (agreement to commit a crime) and 'Substantive Counts' (actual commission of a crime), instructing the jury that these are separate offenses and outlining the order in which specific counts (One through Six) will be addressed.
DOJ-OGR-00008625.jpg
This document is a specific page (page 87 of 167) from a court filing dated December 18, 2021, related to Case 1:20-cr-00330-PAE (USA v. Ghislaine Maxwell). It serves as a Table of Contents for Jury Instructions, listing instructions 49 through 59, covering topics such as the defendant's right not to testify, evidence from searches, electronic communications, and jury conduct.
DOJ-OGR-00008613.jpg
This document is a jury instruction, specifically Instruction No. 53, from a legal case (1:20-cr-00330-PAE) filed on December 18, 2021. The instruction directs the jury on how to consider electronic communications seized by the Government as evidence. It explicitly states that the seizure and use of this evidence are legal, and that the jury must not allow their personal opinions about the seizure to affect their deliberations, but must instead determine the weight of the evidence in deciding the Defendant's guilt.
DOJ-OGR-00008610.jpg
This document is page 72 of 167 from a court filing (Document 563) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 18, 2021. It contains Jury Instruction No. 50, which directs the jury not to draw inferences from uncalled witnesses who were mentioned during the trial but did not testify. It further emphasizes that the defendant bears no burden to call witnesses or produce evidence.
DOJ-OGR-00008596.jpg
This document is a page from a court filing (Case 1:20-cr-00330-PAE), filed on December 18, 2021, which appears to be jury instructions. The text explains the legal doctrine of "conscious avoidance," instructing the jury on how they can find that a defendant acted knowingly if she deliberately avoided learning the truth about her involvement in unlawful conduct or a conspiracy. It clarifies that while conscious avoidance can establish knowledge of a conspiracy's objective, it cannot substitute for the finding that the defendant knowingly and intentionally joined the conspiracy itself.
DOJ-OGR-00008595.jpg
This legal document is a jury instruction, specifically Instruction No. 39, filed on December 18, 2021, in case 1:20-cr-00330-PAE. It defines the concept of "conscious avoidance" or "willful blindness," instructing the jury that they can consider a defendant's deliberate ignorance of a probable crime as the equivalent of actual knowledge. This instruction guides the jury in determining whether the defendant acted "knowingly," a key element the government must prove.
DOJ-OGR-00008561.jpg
This legal document is a jury instruction (Instruction No. 14) from case 1:20-cr-00330-PAE, filed on December 18, 2021. It details the three elements the government must prove beyond a reasonable doubt to convict the defendant on 'Count Two: Enticement to Engage in Illegal Sexual Activity'. The instruction specifies that this charge pertains exclusively to actions against an individual named 'Jane' between 1994 and 1997.
DOJ-OGR-00008557.jpg
This document is a page from a legal filing dated December 18, 2021, outlining two counts of an indictment. Count Five charges an unnamed defendant with conspiring to sex traffic multiple minors between 2001 and 2004. Count Six charges the same defendant with the sex trafficking of a specific individual named Carolyn during the same time period.
DOJ-OGR-00008545.jpg
This document is page 7 of a 167-page legal filing (Document 563) from Case 1:20-cr-00330-PAE, filed on December 18, 2021. It is a table of contents for a set of jury instructions, listing topics from Instruction No. 42 to No. 59, which cover evidence, witness credibility, defendant's rights, and jury conduct.
DOJ-OGR-00008529.jpg
This document is page 73 of 82 from a court filing in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 17, 2021. It contains Jury Instruction No. 54, titled 'Persons Not on Trial,' which explicitly instructs the jury not to speculate why other individuals are not on trial or draw inferences from their absence. The document is stamped with Bates number DOJ-OGR-00008529.
DOJ-OGR-00008528.jpg
This document is a jury instruction, specifically Instruction No. 53, from case 1:20-cr-00330-PAE, filed on December 17, 2021. It directs the jury on how to consider electronic communications seized by the Government as evidence. The instruction clarifies that the use of this evidence is legal, and the jury must not let their personal opinions about the seizure influence their deliberations, but they are responsible for determining the weight of this evidence.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| N/A | Paid | defendant | plaintiff | $5,000,000.00 | Claimed lost wages by Plaintiff. | View |
| N/A | Paid | defendant | N/A | $0.00 | Defendant reported having 'almost no assets' to... | View |
| N/A | Paid | defendant | Virginia | $0.00 | Monetary incentives to encourage Virginia to re... | View |
| N/A | Paid | defendant | Spouse (via trusts) | $0.00 | Moving majority of assets out of her name by fu... | View |
| N/A | Paid | defendant | Yorkville real es... | $0.00 | Ownership of a multi-million dollar foreign pro... | View |
| N/A | Paid | defendant | WorldBank | $0.00 | Ownership of at least one foreign bank account. | View |
| N/A | Paid | defendant | Accounts under ot... | $0.00 | Placing assets into accounts held under other n... | View |
| N/A | Paid | defendant | Credit Card Issuers | $0.00 | Registering at least one credit card under othe... | View |
| N/A | Paid | defendant | Trusts and Husban... | $0.00 | Defendant slowly funneled the majority of her w... | View |
| N/A | Paid | defendant | Court | $500.00 | Mention of fine for misdemeanors. | View |
| N/A | Paid | defendant | plaintiff | $0.00 | Lawsuits seeking millions of dollars from the c... | View |
| N/A | Paid | defendant | Court/Government | $750,000.00 | Proposed fine which is the maximum allowed by law | View |
| N/A | Paid | defendant | Court/State | $20,000.00 | Minimum range for fine per count | View |
| N/A | Paid | defendant | Court/State | $200,000.00 | Maximum range for fine per count | View |
| N/A | Paid | defendant | Underage girls | $0.00 | Payment of underage girls for sex acts | View |
| N/A | Paid | defendant | Sex trafficking s... | $0.00 | Funded a sex trafficking scheme | View |
| N/A | Paid | defendant | Court/Government | $5,000,000.00 | Statutory maximum fine mentioned by the Court. | View |
| N/A | Paid | defendant | Court/Government | $100.00 | Special assessment fee mentioned by the Court. | View |
| N/A | Paid | defendant | Virginia | $0.00 | Defendant used monetary incentives to encourage... | View |
| N/A | Paid | defendant | victim | $0.00 | Hypothetical reference to a defendant paying re... | View |
| N/A | Received | Alleged Victims | defendant | $14.00 | Contents of a wallet involved in a pickpocketin... | View |
| N/A | Received | Unknown | defendant | $10,000.00 | Briefcase containing $10,000 carried by defendant | View |
| N/A | Paid | defendant | Various unnamed g... | $0.00 | Large cash loans made by defendant used as evid... | View |
| N/A | Paid | defendant | plaintiff | $30,000,000.00 | Plaintiff's request for damages mentioned by De... | View |
| 2025-03-01 | Paid | defendant | Marriage Assets | $20,000,000.00 | Amount defendant brought to the marriage (more ... | View |
Request no. 24
Demands all documents concerning assertions that the recipient met Bill Clinton, Al Gore, and Tipper Gore on Little Saint James.
Request no. 1
Demands documents referencing Alan M. Dershowitz supporting allegations in a specific Declaration.
Reply
Dkt. No. 42; acknowledged BOP changes but requested court order confirming them.
Def. Mot.
Argument regarding waiver of right to appeal extradition.
Objection/Surprise
Referenced by Mr. Rohrbach as receiving the defendant's letter with surprise.
Derogatory comments about Jane Doe No. 3
Called Jane Doe No. 3 a 'prostitute,' a 'liar,' or a 'bad mother'.
Incoming calls
Contemporaneous messages taken by staff in spiral bound books.
Document Requests
Included 25 separate document requests, including requests regarding Bill Clinton, Al Gore, and personal diaries.
Request for documents
Seeking broad categories of victim information and communications with the Government.
Change of residence / Compliance
Mandatory reporting of residence changes and following instructions.
Employment Activities
Truthful disclosure of all information regarding activities related to BOP employment.
Contact Restriction
No contact with co-defendant unless in the presence of counsel
Charges
Charges defendant with conspiracies to arrange for sexual activity and commercial sex acts (Paragraphs 12, 18, 24).
Renewed motion for release on bail
Defendant filed a renewed motion for release; Government opposes.
Motion to vacate/Rule 29
Arguments regarding prejudice due to absent witnesses and pre-indictment delay.
Litigation Strategy
Defendant stated they are considering suing the non-party for defamation and that they found her in Colorado to serve her.
Request for Production
Requests for diaries (1999-2002), photographs, and videos from when the non-party was a minor.
Request no. 25
Request for documents concerning retention of Boies, Schiller & Flexner LLP
N/A
Defendant is able to send and receive emails with defense counsel every day.
N/A
Regular communication via VTC (Video Teleconferencing).
Reply to Government response
Asked Court to confirm BOP changes in an order and grant same privileges as other detainees (Dkt. No. 42).
Sentencing Preparation
Defendant refused to provide info on marriage and claimed no assets.
Instruction on Carolyn
Instructed Virginia to show Carolyn 'what to do.'
Communications with the U.S. Attorney and BSF's co-counsel
The document describes a subpoena seeking broad categories of communications, which the author argues is an impermissible 'fishing expedition' that fails to meet the specificity requirements of Rule 17(c).
Defendant's Motion (Def. Mot. 1)
A motion filed by the defendant arguing that Epstein's NPA should preclude prosecution of co-conspirators in other districts.
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