defendant
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
defense counsel/attorneys
|
Client |
5
|
1 | |
|
person
CAROLYN
|
Criminal defendant victim |
5
|
1 | |
|
person
JANE
|
Criminal defendant victim |
5
|
1 | |
|
person
defendant's associates
|
Professional |
5
|
1 | |
|
person
minor
|
Criminal |
5
|
1 | |
|
person
Knowing/Unknowing Participants
|
Supervisory organizational |
5
|
1 | |
|
person
U.S.
|
Legal representative |
5
|
1 | |
|
person
Laura Menninger
|
Client |
5
|
1 | |
|
person
monitor
|
Professional |
5
|
1 | |
|
person
Juror 50
|
Adversarial |
5
|
1 | |
|
location
UNITED STATES OF AMERICA
|
Legal representative |
5
|
1 | |
|
organization
Mortgage Express, Inc.
|
Business associate |
5
|
1 | |
|
person
Juan Alessi
|
Professional |
5
|
1 | |
|
person
CAROLYN
|
Abuser victim alleged intent |
5
|
1 | |
|
person
victims
|
Abusive criminal |
5
|
1 | |
|
person
SARAH KELLEN
|
Co conspirator |
5
|
1 | |
|
person
Annie
|
Abuser victim alleged |
5
|
1 | |
|
person
two individuals
|
Financial |
5
|
1 | |
|
person
Jane
|
Facilitator victim |
5
|
1 | |
|
person
Salhi
|
Legal representative |
5
|
1 | |
|
person
Kate
|
Victim perpetrator |
5
|
1 | |
|
person
Fontanilla
|
Legal representative |
5
|
1 | |
|
person
victim
|
Legal representative |
5
|
1 | |
|
person
his victims and other young females
|
Exploitative |
5
|
1 | |
|
person
Jane
|
Abuser victim alleged |
5
|
1 |
| 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 |
|---|---|---|---|---|---|---|
| 2025-03-01 | Paid | defendant | Marriage Assets | $20,000,000.00 | Amount brought to the marriage by the defendant... | View |
| 2025-03-01 | Paid | defendant | Marriage Assets | $20,000,000.00 | Amount defendant brought to the marriage (more ... | View |
| 2022-06-01 | Paid | defendant | N/A | $22,000,000.00 | Value of assets defendant claimed to have durin... | View |
| 2021-03-22 | Received | Buyers of Hovensa... | defendant | $450,000.00 | Amount the Defendant would retain for living ex... | View |
| 2021-03-22 | Received | Buyers of Hovensa... | defendant | $0.00 | Jewelry and other chattels potentially worth hu... | View |
| 2021-03-09 | Paid | defendant | Monitorship | $0.00 | Defendant offers to place some assets in a moni... | View |
| 2020-12-30 | Paid | defendant | Court | $28,500,000.00 | Proposed bail package (rejected). | View |
| 2020-12-30 | Received | Lender (implied) | defendant | $0.00 | Significant loans procured on the basis of a ne... | View |
| 2020-12-30 | Paid | defendant | Illiquid Hedge Fund | $4,000,000.00 | Investment argued by defense to be difficult to... | View |
| 2020-12-01 | Received | N/A | defendant | $3,400,000.00 | Approximate worth of assets held in defendant's... | View |
| 2020-07-14 | Paid | defendant | Court (Bond) | $0.00 | Discussions regarding a bond, transparency of f... | View |
| 2020-07-01 | Paid | defendant | Self | $3,400,000.00 | Approximate assets held in defendant's own name... | View |
| 2020-07-01 | Paid | defendant | Self | $3,400,000.00 | Approximate assets held in her own name. | View |
| 2019-07-02 | Paid | defendant | United States Gov... | $0.00 | Legal provision declaring intent to seek forfei... | View |
| 2015-01-01 | Paid | defendant | Spouse | $0.00 | Millions of dollars of assets transferred throu... | View |
| 2015-01-01 | Paid | defendant | Spouse | $0.00 | Millions of dollars of assets transferred throu... | View |
| 2009-06-01 | Paid | defendant | plaintiff | $150,000.00 | Damages sought per violation under 2006 amended... | View |
| 2009-06-01 | Paid | defendant | plaintiff | $50,000.00 | Damages minimum under 2005 statute | View |
| 2008-09-18 | Paid | defendant | victims | $150,000.00 | Minimum damages set by 18 U.S.C. § 2255 referen... | View |
| 2008-09-18 | Paid | defendant | Robert Josefsberg... | $0.00 | Defendant required to pay for services of indep... | View |
| 2008-07-17 | Paid | defendant | Code Enforcement ... | $150.00 | Administrative fee mentioned in previous minutes. | View |
| 2008-07-17 | Paid | defendant | Code Enforcement ... | $125.00 | Daily fine rate discussed. | View |
| 2008-07-17 | Paid | defendant | Code Enforcement ... | $150.00 | Administrative fee ordered in previous motion. | View |
No Subject
The document states the defendant has access to email with her defense counsel during her thirteen hours per day of discovery review.
Objection to recapitulation of charges
The Defendant objects to the detailed summary of the six counts, arguing it places unfair emphasis on the charges and requests that if summarized, each count be followed by a statement of Ms. Maxwell's denial and presumption of innocence.
Response to Government objections
The defense incorporates by reference their previous responses and objections to the Government's proposed Introduction and Charges section.
No Subject
The document states the defendant has access to calls with her defense counsel.
No Subject
The defendant is able to send and receive emails with defense counsel every day.
Legal consultation
The defendant has regular communication and conferences with counsel via VTC (Video Teleconferencing).
Opposition to Government's motion (Def. Opp. at 49-57)
The defendant's legal team filed an opposition, which the Government claims largely refuses to respond to their motion and instead offers the defendant's own statements and arguments.
Scheduling appointments
The Defendant would call Carolyn to schedule appointments for her to perform sexualized massages on Epstein.
Legal arguments in the case
The defendant's briefing referenced the letter from Catherine Conrad.
Authentication of evidence
The document cites cases, including United States v. Bertram, where a witness was allowed to authenticate emails based on familiarity with the defendant's communication style, even if they were not a recipient of the specific email.
No Subject
A letter from the defendant is cited (Def. Letter at 6) where it is suggested that the U-Visa form is 'powerful evidence of motive of bias'.
Response to Government's objection regarding 'Media Issue...
The Defendant argues that detailed questioning about media exposure is critical in a high-profile case to ascertain juror bias, citing legal precedents like United States v. Tsarnaev to support the need to identify what content jurors have seen and what they believe they know.
No Subject
The document states that victims received phone calls from the defendant when the victims were between the ages of 14 and 17.
Request no. 24
Demands all documents concerning assertions that the recipient met Bill Clinton, Al Gore, and Tipper Gore on Little Saint James.
Legal Consultation
Defense counsel will be able to schedule legal calls on weekends as needed for the defendant.
Request to strike or seal Juror 50's motion
A motion filed by the Defendant, referred to as 'Defense Motion', requesting that the Court strike or, alternatively, seal Juror 50's motion. The Court denied this request.
Response to Government's objection
The Defendant responds that the questions are necessary because the Court has not ruled on their admissibility, new hardship issues may arise, and asking the questions live allows the parties to observe juror reactions and aids in selecting a fair jury.
Response to Government's objection
The Defendant responds that the questions are necessary because the Court has not ruled on their admissibility, new hardship issues may arise, and asking the questions live allows the parties to observe juror reactions and aids in selecting a fair jury.
Proposed Protective Order
The Defendant submitted a Proposed Protective Order (Dkt. No. 29) which included a provision restricting the use of discovery to the defense of the criminal action.
Request for modification of protective order
After receiving some discovery, the Defendant filed a request to modify the protective order to use documents for purposes other than the criminal defense.
Exhibit 1 (email)
A letter from the defendant to which a specific email was attached as Exhibit 1.
Legal consultation
The document states that MDC legal counsel has assured the Government that MDC staff does not record or listen to the substance of the defendant's calls and visits with her legal counsel.
Legal consultation
The document states that MDC legal counsel has assured the Government that MDC staff does not record or listen to the substance of the defendant's calls and visits with her legal counsel.
response to jury note
Defendant failed to propose a legally accurate response to the jury's note.
N/A
Defendant is able to send and receive emails with defense counsel every day.
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