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 |
DOJ-OGR-00001657.jpg
This document is a page from a court order (Case 1:20-cr-00330-AJN) filed on July 27, 2020, detailing the strict protocols for handling confidential discovery materials. It specifies that the Defendant and their legal team are restricted in how they can review, possess, copy, and file this information, requiring authorization from the Government or the Court for public disclosure. The order also mandates that all discovery materials be returned or destroyed at the end of the case.
DOJ-OGR-00001655.jpg
This document is page 9 of a court filing (Document 29-1) from July 27, 2020, in Case 1:20-cr-00330-AJN (US v. Ghislaine Maxwell). It outlines strict protocols for the handling of discovery materials, specifically those designated as 'Highly Confidential Information.' It details that the Defendant may only review materials in the presence of counsel or BOP officials, and sets rules for showing materials to potential defense witnesses via read-only means without providing physical copies.
DOJ-OGR-00001650.jpg
This legal document, part of case 1:20-cr-00330-AJN filed on July 27, 2020, is a court order outlining the protocol for handling discovery materials. It specifies that the Defendant and Defense Counsel can share materials with authorized third parties—such as experts, advisors, and potential witnesses—provided these individuals formally agree in writing to be bound by the order's confidentiality terms.
DOJ-OGR-00001629.jpg
This document is the conclusion page of a legal filing (Document 22) dated July 13, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The Government argues that the defendant poses an extreme flight risk and requests that any application for bail be denied. It is signed by Assistant US Attorney Alison Moe on behalf of Acting US Attorney Audrey Strauss and colleagues Alex Rossmiller and Maurene Comey.
DOJ-OGR-00001625.jpg
This document is page 15 of a Government memorandum filed on July 13, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The prosecution argues against granting bail, citing that the MDC is adequately handling COVID-19 risks and referencing legal precedents where bail was denied despite the pandemic. A footnote emphasizes the Government's position that the defendant has the financial means to flee the country and that pandemic travel restrictions would not prevent her flight.
DOJ-OGR-00001562.jpg
This is a court order from United States District Judge Alison J. Nathan, dated July 9, 2020, for case 1:20-cr-00330-AJN. The order establishes procedures for court proceedings amidst the COVID-19 pandemic, limiting seating to approximately 60 people on a first-come, first-served basis and outlining how counsel and the press can make seating requests. The document strictly prohibits any photographing, recording, or rebroadcasting of the proceedings, warning that violations may result in fines, sanctions, or denial of entry to future hearings.
DOJ-OGR-00001533.jpg
This is the signature page (page 2 of 4) of a court order filed on July 6, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). Judge Alison J. Nathan orders the submission of a letter proposing a date for proceedings and a revised schedule for the Defendant's bail application. The document bears a DOJ production stamp.
DOJ-OGR-00001498.jpg
This document is the second page of a legal letter filed on July 5, 2020, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The US Attorney's office requests Judge Nathan exclude time under the Speedy Trial Act to allow for the transportation of the defendant from another district and to facilitate discussions regarding a protective order to shield the identities of victims and third parties during discovery. Defense counsel consented to this request.
DOJ-OGR-00001279.jpg
This legal document is a court order from March 22, 2021, reaffirming the decision to detain a defendant. The Court concludes that the Government has shown the defendant is a flight risk and that no proposed conditions can reasonably assure her appearance. The Court's assessment of the factors under 18 U.S.C. § 3142(g), including the presumption of detention and the weight of the evidence, remains unchanged despite the defendant's new arguments.
DOJ-OGR-00001250.jpg
This legal document argues against a defendant's proposed bail conditions, asserting that her financial proposal is vague and would leave her with ample resources (over $3.5 million plus future income) to flee prosecution. The filing contends that the proposed financial monitorship creates a conflict of interest and that the defendant's pending pretrial motions do not weaken the strength of the government's case. The author urges the Court to reject the defendant's proposal, concluding she remains a significant flight risk.
DOJ-OGR-00001246.jpg
This legal document is a court filing arguing against a defendant's third motion for release on bail. The author, likely the prosecution (Government), contends that the defendant remains an extreme flight risk due to strong evidence, substantial resources, and foreign ties to a non-extraditing country. The document dismisses the defendant's new proposals—renouncing foreign citizenship and placing some assets under monitorship—as insufficient to ensure their appearance in court and urges the motion to be denied.
DOJ-OGR-00001229.jpg
This legal document is a court ruling denying a defendant's request for release from pre-trial detention. The Court finds that the government has shown the defendant is a flight risk and rejects her argument that her conditions of confinement, including a recent COVID-19 lockdown, unconstitutionally interfere with her ability to prepare her defense. The Court concludes she has been given adequate time and resources to communicate with her attorneys.
DOJ-OGR-00001225.jpg
This legal document outlines a court's reasoning for continuing the pretrial detention of a defendant. The Court finds that the defendant has demonstrated a significant 'lack of candor' regarding her finances, particularly in representations made to Pretrial Services, and therefore poses a flight risk. A proposed $28.5 million bail package is deemed insufficient to reasonably assure her appearance at future proceedings.
DOJ-OGR-00001170.jpg
This document is page 28 of a court filing (Case 1:20-cr-00330-AJN, United States v. Ghislaine Maxwell) filed on December 18, 2020. The Government argues against granting the defendant's bail package, asserting that she has transferred the majority of her wealth to her husband over the last five years, meaning any bond posted by him would essentially be her own money, reducing the 'moral suasion' preventing flight. The document cites legal precedent (United States v. Boustani) rejecting a 'two-tiered bail system' that favors wealthy defendants who can afford private security.
DOJ-OGR-00001155.jpg
This legal document discusses the corroboration of victims' accounts against a defendant involved in Epstein's criminal scheme to sexually abuse minors. It addresses the defense's arguments regarding the sufficiency of evidence and witness testimony, asserting that multiple victims will provide consistent testimony about the defendant's role in grooming and enticing minor girls. The document also notes that the defendant has abandoned certain legal challenges related to bail after receiving discovery.
DOJ-OGR-00001084.jpg
This legal document, dated April 1, 2021, is a transcript or filing that outlines the legal framework for a court to order a defendant's detention under U.S. Code Section 3142. It specifies that detention is ordered if no conditions can assure the defendant's appearance and community safety, detailing the standards of evidence for dangerousness and flight risk, and explaining the defendant's burden of production to rebut a presumption of detention as clarified by the Second Circuit.
DOJ-OGR-00001079.jpg
This document is a page from a court transcript dated April 1, 2021, from Case 21-770 (United States v. Ghislaine Maxwell). Prosecutor Ms. Moe argues that the defendant poses a flight risk and has failed to meet the burden of production to rebut the presumption of detention, citing recommendations from Pretrial Services and victims' requests. The Judge questions Ms. Moe regarding defense attorney Mr. Cohen's arguments about the government's burden of proof regarding flight risk.
DOJ-OGR-00001053.jpg
This document is an excerpt from a legal transcript dated April 1, 2021, where an attorney argues about bail conditions for a defendant. The attorney references several legal precedents (Khashoggi, Bodmer, Hanson, Sabhnani) to assert that international ties and financial means should lead to stricter bail conditions, not a denial of bail. The current defendant is described as a citizen of England and France with three passports, who has traveled internationally and has financial means, and the attorney cites the Sabhnani case, which involved allegations of holding individuals in slavery, to support their argument regarding bail.
DOJ-OGR-00001041.jpg
This document is a court transcript from April 1, 2021, detailing the government's argument for detaining a defendant pending trial. The government's representative, Ms. Moe, asserts the defendant is an extreme flight risk, citing her possession of three passports, large sums of money, and international connections. The court clarifies that the government's argument is based solely on flight risk and not on any danger the defendant poses to the community.
DOJ-OGR-00001038.jpg
This document is a page from a court transcript dated April 1, 2021, where a speaker, Ms. Moe, is arguing that the defendant is a flight risk. Ms. Moe presents evidence of the defendant's significant wealth, citing bank records from January 2019 that show an annual income between $200,000 and $500,000, a net worth over $10 million, and a trust account with over $4 million in assets.
DOJ-OGR-00001032.jpg
This document is a transcript from a court case, specifically a discussion regarding the defendant's financial information. The court questions Ms. Moe about the defendant's reported income and the government's perspective on its plausibility.
DOJ-OGR-00001028.jpg
This document is a page from a court transcript dated April 1, 2021. In it, a speaker, likely a prosecutor, argues before a judge about the seriousness of the charges against an unnamed defendant. The allegations, detailed from an indictment, include transporting and enticing minors for sexual abuse, perjury, and conspiring with Jeffrey Epstein to sexually exploit girls as young as 14.
DOJ-OGR-00001027.jpg
This document is a page from a court transcript (Case 21-770) involving a detention hearing. Prosecutor Ms. Moe argues that the female defendant (implied to be Ghislaine Maxwell) should be denied bail because she poses an extreme flight risk, has significant undisclosed financial means, strong international ties, and is charged with the sexual abuse of minors. Defense attorney Mr. Cohen is present, and the judge indicates that alleged victims will also be heard.
DOJ-OGR-00001011.jpg
This document is a page from a court transcript dated April 1, 2021, concerning Case 21-770. It details a discussion between the Judge, Ms. Moe (Government), and Mr. Cohen regarding the necessity of conducting the arraignment and bail hearing remotely due to the COVID-19 pandemic. The Court affirms that the proceeding cannot be delayed as the detained defendant is seeking bail and notes the significant public interest in the case.
DOJ-OGR-00000974.jpg
This legal document argues that Ms. Maxwell is not a flight risk, citing prior court decisions where defendants who knew of impending charges did not flee. It emphasizes that the government had no evidence of Ms. Maxwell planning to leave the country and arrested her without warning before a holiday. The document further contends that Ms. Maxwell's actions to avoid public scrutiny after Epstein's arrest do not indicate an intent to flee.
| 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 |
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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