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-00000948.jpg
This document provides the background for a federal indictment returned on June 29, 2020, charging the defendant (Ghislaine Maxwell) with conspiracy, enticing minors for illegal sex acts, and perjury. It describes a scheme operating between 1994 and 1997 in New York, Florida, and New Mexico, where the defendant allegedly groomed underage girls to be sexually abused by Jeffrey Epstein. The text details specific grooming tactics used, such as befriending victims and taking them on shopping trips to normalize the abuse.
DOJ-OGR-00000873.jpg
This legal document, filed on September 22, 2021, is a court memorandum outlining the Court's rejection of the Defendant's proposed conditions to mitigate her flight risk. The Court finds that the Defendant's offers to renounce her UK and French citizenship and to have a retired federal judge oversee her finances are insufficient to assure her appearance at future proceedings. The Court remains concerned about her ability to delay or resist extradition, especially given her substantial international ties.
DOJ-OGR-00000871.jpg
This legal document is a court opinion denying a defendant's third motion for bail. The Court concludes that the defendant remains a significant flight risk, and her new proposals—renouncing her French and British citizenship and placing assets in an account monitored by a retired judge—are insufficient to mitigate this risk. The Court highlights the unclear validity and practical impact of the citizenship renunciations, particularly citing a French official's opinion that being a French national is an "insuperable obstacle" to removal.
DOJ-OGR-00000866.jpg
This legal document is a court filing from September 22, 2021, detailing the procedural history of a defendant's third motion for release on bail. It outlines the dates of the defendant's motion, the government's opposition, and the defendant's reply. The document then discusses the legal standard regarding the court's jurisdiction to rule on the bail motion while the defendant's bail appeal is pending in a higher court.
DOJ-OGR-00000613.jpg
This document is page 2 of a court transcript from Case 1:19-cr-00490-RMB (United States v. Jeffrey Epstein), filed on August 6, 2019. The text details a scheduling conference where prosecutor Ms. Moe proposes an October 31 deadline for discovery. She notes a specific exception regarding materials seized from the defendant's New York residence, which the F.B.I. is currently reviewing, necessitating a privilege-review protocol with defense counsel.
DOJ-OGR-00000601.jpg
This document is page 7 of a Protective Order from a legal case (1:19-cr-00490-RMB), filed on July 25, 2019. It details the rules for handling confidential information by the Defendant and Defense Counsel, including restrictions on possession, inspection under law enforcement protection, and a prohibition on duplication. The order also specifies the procedure for sharing information with 'Designated Persons' and requires the eventual return or destruction of all discovery materials to the Government.
DOJ-OGR-00000599.jpg
This document is page 5 of a legal filing (Case 1:19-cr-00490-RMB) dated July 25, 2019. It defines "Confidential Information," which can include personal data and witness identities, and sets forth strict rules for how this information must be handled by the defendant and their Defense Counsel. The rules govern the use, storage, review, and disclosure of the sensitive material throughout the legal proceedings.
DOJ-OGR-00000592.jpg
This is page 7 of a court filing (Document 37-1) from Case 1:19-cr-00490-RMB (United States v. Jeffrey Epstein), filed on July 25, 2019. It outlines strict protocols for a Protective Order regarding discovery materials, specifically prohibiting the Defendant from possessing materials outside the presence of counsel or copying them. It also establishes requirements for 'Designated Persons' to sign agreements before receiving confidential information and mandates the return or destruction of discovery materials at the case's conclusion.
DOJ-OGR-00000591.jpg
This document is a page from a court order filed on July 25, 2019, in case 1:19-cr-00490-RMB. It defines 'Highly Confidential Information' as including images of nude or partially-nude individuals and sets forth strict rules for its handling by the defense. The order explicitly states that this information cannot be copied or disseminated and that the Defendant is only permitted to review it under the direct supervision of their defense counsel.
DOJ-OGR-00000590.jpg
This legal document, part of case 1:19-cr-00490-RMB filed on July 25, 2019, establishes the rules for handling "Confidential Information." It dictates that the defendant's counsel is responsible for the secure maintenance of this information and outlines strict limitations on how the defendant can access it and to whom it can be disclosed, such as Designated Persons and Potential Witnesses.
DOJ-OGR-00000588.jpg
This document is page 3 of a protective order filed on July 25, 2019, in the case of United States v. Jeffrey Epstein (Case 1:19-cr-00490). It outlines strict protocols for handling discovery materials, including requirements for encryption when sharing with staff and a specific prohibition against the Defendant, Government, or Counsel posting any discovery information on the Internet or social media. It also specifies that potential witnesses may view materials for trial preparation but cannot retain copies.
DOJ-OGR-00000573.jpg
This document is a transcript from a court proceeding on July 24, 2019, in the case 1:19-cr-00490-RMB. An unidentified speaker, likely a prosecutor, argues against the defense's interpretation of a federal Non-Prosecution Agreement (NPA) and the definition of the crime, emphasizing that the case involves sex trafficking of underage girls, which makes the defense's arguments about consent legally irrelevant and offensive.
DOJ-OGR-00000571.jpg
This is page 61 of a court transcript from the Jeffrey Epstein case (1:19-cr-00490-RMB), filed on July 24, 2019. Prosecutor Rossmiller argues before the Court that pre-trial detention does not prevent a defendant from preparing a robust defense, citing the 'Zarrab' case as a precedent where a detained defendant had ample access to counsel and document review. The prosecution expresses willingness to consider factors like space and document review capabilities for the defendant.
DOJ-OGR-00000529.jpg
This document is a page from a court transcript dated July 24, 2019. In it, an attorney named Mr. Rossmiller responds to the Court, stating that Florida police reports suggest the defendant harassed individuals through agents or investigators. Mr. Rossmiller also explains that the government took no position on the defendant's application to seal financial information because they were unsure what would be submitted and had little time to respond.
DOJ-OGR-00000528.jpg
This document is a page from a court transcript dated July 24, 2019. In it, a representative for the government argues against a defendant's release, citing a significant danger to victims and witnesses. The government alleges the defendant previously instructed people to lie to law enforcement and has recently sent hundreds of thousands of dollars to two individuals, supported by police reports from Florida.
DOJ-OGR-00000522.jpg
This document is a page from a court transcript dated July 24, 2019. A prosecutor is arguing to a judge that the defendant should be detained, citing evidence of witness tampering through payments to associates, and highlighting that the defendant is an 'extraordinary flight risk' due to his immense wealth (over $500 million), six homes, two private islands, and a residence in France.
DOJ-OGR-00000521.jpg
This document is a page from a court transcript dated July 24, 2019, detailing a bail hearing. The prosecution, represented by Mr. Rossmiller, argues that the defendant should be detained, citing the defense's failure to provide detailed financial information and the legal presumption of detention for sex trafficking charges, which is strengthened by the defendant's prior sex offense conviction. The judge interacts with the prosecutor to clarify the government's burden of proof in the matter.
DOJ-OGR-00000501.jpg
This legal document, filed on July 18, 2019, critiques Mr. Epstein's proposed bail package, arguing that his home confinement plan involves excessive judicial oversight and raises practical concerns about private security. It also dismisses the defense's offer of an anticipatory extradition waiver as an 'empty gesture,' citing the Department of Justice's view that such waivers are not binding and the risk of the defendant fleeing to a non-extradition jurisdiction.
DOJ-OGR-00000420.jpg
This document is a transcript from a court hearing (Case 1:19-cr-00490-RMB) filed on July 16, 2019. Attorney Mr. Weingarten argues before the Court that the Florida nonprosecution agreement should stand, asserting that a plea deal cannot be undone simply because prosecutors failed to notify victims, provided the defendant fulfilled their obligations (prison time, restitution, registration). Weingarten emphasizes that voiding such deals would make it impossible for defense attorneys to negotiate future agreements.
DOJ-OGR-00000369.jpg
This document is a transcript from a SORA (Sex Offender Registration Act) hearing on July 15, 2019. The dialogue is between Ms. Gaffney and the Court, discussing whether the lack of an indictment by the prosecutor's office constitutes strong evidence that an offense did not occur. The Court expresses surprise at the prosecutor's actions and a 'Level Three' finding by a risk assessment board, finding the situation unprecedented.
DOJ-OGR-00000338.jpg
This legal document is a portion of a prosecution filing arguing against granting bail to a defendant. The prosecution asserts that the defendant's wealth should not permit him to create a private, guard-monitored home confinement, citing legal precedent. It further argues the defendant poses an ongoing danger to the community, referencing a prior conviction for a sex crime with a minor and the discovery of a large collection of sexually suggestive photographs of underage females at his residence.
DOJ-OGR-00000270.jpg
This document is page 13 of a legal filing (Indictment) dated July 2, 2019, for Case 1:19-cr-00490-RMB (the Jeffrey Epstein case). It outlines the 'Substitute Asset Provision,' stating the government's intent to seize other property from the defendant if the primary forfeitable assets are missing, transferred, or devalued. The document is signed by the Grand Jury Foreperson and U.S. Attorney Geoffrey S. Berman.
DOJ-OGR-00000022.jpg
This document is page 21 of a legal opinion from Case 22-1426 (United States v. Maxwell), dated September 17, 2024. The text discusses the legal concept of 'constructive amendment' regarding the indictment, specifically analyzing 'Jane's testimony' and a 'jury note' related to Count Four. The appellate court agrees with the District Court's handling of the jury instructions and determines that the core of criminality was properly maintained.
DOJ-OGR-00030375.jpg
This document is a page from a legal statute, specifically ¹943.0435, defining the term "Sexual offender." It outlines four main criteria for this classification, which involve convictions for a list of specific statutes, release from sanctions after October 1, 1997, residency status combined with out-of-state predator designations, or juvenile delinquency adjudications after July 1, 2007. The definition is comprehensive, covering various scenarios and legal statuses to determine who is required to register with the department.
DOJ-OGR-00021105.jpg
This legal document argues that the Appellant's convictions for Mann Act violations (Counts Three and Four) must be vacated. The argument centers on the statute of limitations, asserting that the extension under § 3283 does not apply because it is limited to offenses involving a 'child,' whereas the Defendant's accusers were adults over 25 when charges were filed in 2020.
| 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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