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 | Health event | The defendant was potentially exposed to COVID-19, was placed in quarantine, remained asymptomati... | MDC | View |
| N/A | Legal hearing | An initial bail hearing was held where the Court found the defendant had no underlying health con... | N/A | View |
| N/A | Security search | The defendant is subjected to routine searches, including after visits, of her cell, pat downs wh... | MDC | View |
| N/A | Legal motion | Defendant filed a motion for a new trial and requested it be kept completely under seal. | N/A | View |
| N/A | Legal proceeding | The Court rejected the Defendant's request for specific jury instructions during a charging confe... | N/A | View |
| N/A | Jury instruction | Instruction No. 23 clarifies the legal standard for Counts Two and Four, stating that the failure... | N/A | View |
| N/A | Legal proceeding | Initial bail hearing for the Defendant. | N/A | View |
| N/A | Legal action | The Defendant's arrest. | N/A | View |
| N/A | Trip | Transporting Jane and other underage girls to New York with the intention that sexual activity wo... | New York | View |
| N/A | Legal proceeding | The Government's summation at trial, where it argued the Defendant intended for victims to be sex... | Court | View |
| N/A | Legal proceeding | The jury convicted the Defendant. | Court | View |
| N/A | Indictment | A grand jury returned an indictment against the defendant for sex trafficking and sex trafficking... | N/A | View |
| N/A | Bail hearing | A bail hearing is mentioned where victims have the opportunity to testify. | court | View |
| N/A | Legal proceeding | The Government's response regarding a defendant's access to a laptop at an MDC facility. | Southern District of New York | View |
| N/A | Indictment | The S2 Indictment charged the defendant with Mann Act offenses. | N/A | View |
| N/A | Trial | The Court charged the jury that the Government had to prove the defendant's intent to violate a N... | N/A | View |
| N/A | Jury selection | The voir dire process where prospective jurors were questioned. The document analyzes this proces... | N/A | View |
| N/A | Trip | Jane's travel to New York, which is the subject of the enticement charges. | New York | View |
| N/A | Trial | A trial where Carolyn testified about being assaulted by Epstein. | N/A | View |
| N/A | Recruitment | The defendant recruited Giuffre to Epstein's Palm Beach property under the guise of hiring her as... | Palm Beach | View |
| N/A | Deposition | A deposition in the civil suit where the defendant allegedly gave perjurious statements. | N/A | View |
| N/A | Trial | A criminal trial where the Court gave instructions to the jury regarding charges against the Defe... | N/A | View |
| N/A | Seizure | Diamonds and cash were seized from a safe in the defendant’s Manhattan residence by law enforceme... | defendant’s Manhattan resid... | View |
| N/A | Crime | Trafficking and abuse of minor victims Virginia Roberts and Melissa. | N/A | View |
| N/A | Trial | A trial where the Government presented evidence about a pattern of abuse involving the Defendant ... | N/A | View |
DOJ-OGR-00008526.jpg
This document is page 70 of 82 from a court filing (Document 562) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 17, 2021. It contains Jury Instruction No. 51, which clarifies that the Government is not legally required to use specific investigative techniques to prove its case. The instruction directs the jury to focus solely on whether the evidence presented proves the defendant's guilt beyond a reasonable doubt.
DOJ-OGR-00008512.jpg
This legal document, likely a jury instruction from Case 1:20-cr-00330-PAE, clarifies the legal concept of 'conscious avoidance' in the context of conspiracy charges. It distinguishes between knowingly participating in a conspiracy and merely knowing its objective, explaining that conscious avoidance can be considered for the latter but not as a substitute for proving intentional joining of a conspiracy. The document provides guidance on how to assess a defendant's knowledge and actions regarding a conspiracy.
DOJ-OGR-00008511.jpg
This legal document is a jury instruction (Instruction No. 39) from a criminal case, filed on December 17, 2021. It defines the legal concept of "conscious avoidance" or "willful blindness," explaining to the jury how a defendant's deliberate act of ignoring facts can be considered the legal equivalent of knowledge. The instruction clarifies that this is a factor the jury can use to determine if the defendant acted "knowingly," a required element for the crimes charged by the Government.
DOJ-OGR-00008477.jpg
This legal document is a jury instruction (Instruction No. 14) from a court case filed on December 17, 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 relates to actions involving an individual named 'Jane' between 1994 and 1997.
DOJ-OGR-00008473.jpg
This is page 17 of 82 from a legal filing (Document 562) in Case 1:20-cr-00330-PAE, filed on December 17, 2021. The text clarifies that Count Six of the indictment charges the Defendant with sex trafficking of minors specifically regarding an individual named Carolyn during the time period of 2001 to 2004.
DOJ-OGR-00008358.jpg
This legal document, filed on December 12, 2021, is a request from the Government to the Court in case 1:20-cr-00330-PAE. The Government asks the Court to order the defense to provide a chronologically ordered witness list by specific deadlines, arguing that the alphabetical list of thirty-five witnesses already provided is insufficient for trial preparation. The Government contrasts this with its own prior, more detailed disclosures to the defense.
DOJ-OGR-00008276.jpg
This legal document, filed on December 9, 2021, addresses the authentication and admissibility of Government Exhibit 52, described as a 'book' or 'household manual' belonging to Epstein and Maxwell. It discusses the defendant's challenge to Alessi's knowledge regarding the exhibit's origins and highlights the manual's contents, which detail practices and relationships between the defendant, Epstein, and other individuals. The document asserts that authentication does not require direct knowledge of creation or seizure, and chain of custody issues pertain to weight rather than admissibility.
DOJ-OGR-00008242.jpg
This document is page 6 of a legal filing from the Ghislaine Maxwell trial (Case 1:20-cr-00330), dated December 6, 2021. It argues against the defense's claim that a witness named Jane waived her attorney-client privilege regarding advice received from her lawyer, Glassman, about cooperating with the government. The text asserts that Jane did not authorize a waiver, did not testify about privileged communications, and that any statements made by Glassman to the government do not constitute a subject matter waiver for Jane.
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-00001911.jpg
This document is a transcript from a court proceeding filed on December 10, 2020. In it, a speaker identified as Ms. Moe argues that the defendant is a flight risk due to significant financial resources. Ms. Moe cites bank records from January 2019 showing the defendant's annual income is between $200,000 and $500,000, net worth is over $10 million, and that the defendant is the grantor of a trust with over $4 million in assets.
DOJ-OGR-00001830.jpg
This document is page 3 of a court filing (Case 1:20-cr-00330-AJN) filed on November 6, 2020, likely in the prosecution of Ghislaine Maxwell. The Government argues regarding discovery deadlines, agreeing to a laptop for the defendant to review evidence at the MDC but refusing early disclosure of witness lists (Giglio/Jencks material) seven months before trial. The text details upcoming discovery productions, specifically mentioning thousands of images/videos from Epstein's electronic devices, portions of seized iPads and an iPhone, and documents from the FBI's Florida files.
DOJ-OGR-00001823.jpg
This legal document, dated November 6, 2020, details a negotiation between defense counsel and the Government regarding an extension in case 1:20-cr-00330-AJN. The defense proposed four conditions for an extension, including extending motion deadlines and providing discovery materials and victim names. The Government agreed to only two of the conditions, resulting in an inability to reach an agreement on the requested two-week extension for production. The document is certified by Assistant United States Attorney Maurene Comey.
DOJ-OGR-00001781.jpg
This document is the final page (Page 3) of a legal filing (Document 60) submitted on October 6, 2020, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Government, represented by Acting US Attorney Audrey Strauss and Assistant US Attorneys Comey, Moe, and Pomerantz, requests a delay in disclosing witness identities and sensitive materials to the defense to prevent jeopardizing the ongoing investigation and to encourage victims to come forward. The filing cites Rule 16(d) as the legal basis for this protective measure.
DOJ-OGR-00001750.jpg
This page from a court document outlines the procedural history regarding the modification of civil protective orders to comply with criminal grand jury subpoenas. It details the Court's decision to permit the defendant to provide specific information under seal to other relevant courts (Court-1 and Court-2) to determine if materials should be unsealed.
DOJ-OGR-00001700.jpg
This legal document, part of case 1:20-cr-00330-AJN filed on July 30, 2020, outlines the procedures for handling discovery materials post-trial. It mandates that the Defense Counsel must return or destroy all discovery, including confidential information, within 30 days of the case's final resolution. The document also requires the Government and Defense Counsel to meet before any hearings or trial to agree on the presentation of evidence.
DOJ-OGR-00001699.jpg
This document is page 10 of a court order filed on July 30, 2020, in case 1:20-cr-00330-AJN. It details strict regulations for the handling of confidential discovery materials by the Defendant and their legal team, prohibiting dissemination, copying, and public filing unless authorized in writing by the Government or by a specific Order of the Court. The order also specifies that information identifying victims or witnesses is an exception and should not be disclosed.
DOJ-OGR-00001698.jpg
Page 9 of a court order (Protective Order) from case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The document defines 'Highly Confidential Information' as materials containing sexualized images of individuals and outlines the strict limitations on its use, specifically prohibiting use in civil proceedings. It also establishes the protocol for the Defense Counsel to challenge the Government's classification of such materials.
DOJ-OGR-00001697.jpg
Page 8 of a Protective Order filed on July 30, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The document outlines strict protocols for the Defendant's review of discovery materials, mandating supervision by Defense Counsel or BOP officials, and defines the handling of 'Highly Confidential Information,' prohibiting the dissemination of copies to potential witnesses.
DOJ-OGR-00001696.jpg
Page 7 of a court filing (Case 1:20-cr-00330-AJN, filed July 30, 2020) detailing a protective order regarding 'Confidential Information.' The text stipulates that the Defendant (identified as female) may only use such information for this specific criminal defense (not civil proceedings), may only review hard copies in the presence of Defense Counsel, and may only access electronic copies via the Bureau of Prisons (BOP).
DOJ-OGR-00001692.jpg
This document is page 3 of a court filing (Document 36) from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on July 30, 2020. It outlines the protocols for a Protective Order regarding the handling of Discovery materials, defining categories of authorized recipients such as 'Defense Experts/Advisors' and 'Potential Defense Witnesses.' It explicitly mandates that anyone receiving these materials must sign an agreement to be bound by the terms of the Order and prohibits the further distribution of discovery materials.
DOJ-OGR-00001691.jpg
This document is page 2 of a court order filed on July 30, 2020, in a criminal case. The order establishes strict rules for how discovery materials, provided by the Government, are to be handled by the Defendant and their Defense Counsel. It limits the use of these materials strictly to the defense of the current criminal action and restricts their distribution to specific 'Designated Persons' such as paralegal and investigative staff.
DOJ-OGR-00001680.jpg
This document is a page from a court order filed on July 28, 2020, detailing the strict rules and procedures for the handling of confidential and highly confidential information by the defendant and their legal team. It prohibits the public filing of discovery materials unless explicitly authorized by the Government or by a court order, and specifies that materials must be reviewed under controlled conditions. The order aims to protect sensitive information, including victim and witness identities, during legal proceedings.
DOJ-OGR-00001679.jpg
This document is page 9 of a court filing (Document 33-1) from Case 1:20-cr-00330-AJN (USA v. Ghislaine Maxwell), filed on July 28, 2020. It outlines the protocols for handling 'Highly Confidential Information,' specifically defining it as materials containing sexualized images of individuals. It establishes that such information is to be used solely for the criminal defense and not for any civil proceedings.
DOJ-OGR-00001677.jpg
This page from a legal document, filed on July 28, 2020, outlines the rules for handling confidential information in a criminal case (Case 1:20-cr-00330-AJN). It stipulates that such information must be used solely for the defense, kept secure, and details specific protocols for how the defendant can access it in both hard copy and electronic formats, the latter involving the Bureau of Prisons. The Government's confidentiality designations are binding unless overturned by the Court.
DOJ-OGR-00001673.jpg
This document is page 3 of a legal order filed on July 28, 2020, for case 1:20-cr-00330-AJN. It specifies the categories of individuals, such as defense staff, experts, and potential witnesses, who are authorized to receive discovery materials from the defendant's counsel. The order mandates that any person receiving these materials must first sign a copy of the order, explicitly agreeing to be bound by its terms to ensure confidentiality.
| 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.
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein entity