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-00021103.jpg
This legal document presents an argument that all charges against the Appellant should be dismissed because they are barred by the five-year statute of limitations for noncapital offenses. The document contends that the Government's reliance on a specific exception (18 U.S.C. § 3283) for crimes against children is an overreach and warns that a broad interpretation of this statute could have significant negative consequences within the judicial circuit.
DOJ-OGR-00021094.jpg
This legal document argues that the government is precluded from charging the Appellant under Count Six due to a prior Non-Prosecution Agreement (NPA). The argument is based on legal precedent against prosecuting the same crime in a new district and asserts that the charge, involving the trafficking of a witness named Carolyn, falls within the time period covered by the NPA. The document also references a court's finding that the NPA covers Maxwell's involvement in offenses committed by Epstein.
DOJ-OGR-00021089.jpg
This page is from a legal filing (Case 22-1426, dated Feb 28, 2023) arguing that the Non-Prosecution Agreement (NPA) signed by Jeffrey Epstein should be interpreted under Eleventh Circuit law rather than Second Circuit law. The text asserts that under Eleventh Circuit precedent, the NPA's promise by 'the United States' not to prosecute Epstein's potential co-conspirators (specifically including the Defendant) is binding on all U.S. Attorneys' Offices and any ambiguity must be resolved against the government.
DOJ-OGR-00021087.jpg
This legal document is a page from a defendant's brief arguing that the court made an error. The defendant contends the court improperly applied the 'Annabi' rule from the Second Circuit to a Non-Prosecution Agreement (NPA) that was negotiated in Florida, which falls under the Eleventh Circuit. The argument is that since the NPA was negotiated with Florida prosecutors in exchange for Epstein's guilty plea in a Florida state court, Eleventh Circuit law should apply instead.
DOJ-OGR-00021072.jpg
This page from a legal appellate brief (Case 22-1426, dated Feb 28, 2023) argues two main points regarding the Defendant's conviction and sentencing. First, it claims the Court failed to correct a juror misunderstanding regarding 'Count Four,' specifically whether the illegal sexual activity involving victim 'Jane' had to occur in New York versus New Mexico. Second, it argues the sentencing guidelines were miscalculated, specifically disputing an 'aggravating role adjustment' regarding the supervision of another criminal participant.
DOJ-OGR-00021071.jpg
This document is page 24 of an appellate brief (Case 22-1426, dated Feb 28, 2023) arguing two main points: first, that the statute of limitations had expired for the offenses charged because the 2003 amendment to §3283 cannot be applied retroactively to offenses committed before its enactment. Second, it argues for a new trial based on juror misconduct, specifically that a juror lied on a questionnaire to conceal his own history as a victim of child sexual abuse, which the defense argues established bias.
DOJ-OGR-00021065.jpg
This legal document, dated February 28, 2023, is part of a court case (22-1426) and questions the legal basis of a sentence imposed by the District Court. The document raises two key issues: whether the sentence was based on a miscalculated guideline range without proper explanation for an upward variance, and whether the court erred in applying an aggravating role adjustment for supervising another criminal participant without sufficient evidence.
DOJ-OGR-00021064.jpg
This document is a 'Statement of the Issues Presented for Review' from an appellate brief (Case 22-1426, dated Feb 28, 2023). It outlines four main legal arguments for appeal: the misapplication of a non-prosecution agreement, errors regarding statutes of limitations, juror misconduct involving concealed history of sexual abuse, and a constructive amendment of the indictment regarding venue (New Mexico vs. New York) and state law.
DOJ-OGR-00021040.jpg
This legal document is a judicial analysis regarding the sentencing of a defendant. The judge concludes that the evidence, including message pads, does not sufficiently prove the offense continued after November 1, 2004, and therefore the 2003 sentencing guidelines must apply instead of the 2004 guidelines. The judge then begins to address the defendant's objections to specific sentencing enhancements under the 2003 guidelines, confirming that the requirements for an enhancement under 4B1.5(b) have been met.
DOJ-OGR-00021032.jpg
This court transcript excerpt discusses the roles and relationships of individuals involved in a scheme, specifically focusing on the defendant's leadership over Sarah Kellen and their shared association with Jeffrey Epstein and Maxwell. It highlights evidence from flight records showing the defendant and Sarah Kellen traveling on Epstein's private jet, indicating an overlap in their involvement as close associates in an ongoing scheme. The discussion also touches upon legal arguments regarding the supervision of criminal participants.
DOJ-OGR-00021025.jpg
This legal document is a page from a court filing arguing against a defendant's claim of prejudice due to the death of potential witnesses. The prosecution contends that the defendant's assertions about what these witnesses (architects and a housekeeper) would have testified are speculative and unsubstantiated. It further argues that other witnesses, such as Juan Alessi, Larry Visoski, and David Rodgers, were available and did testify about similar matters, like renovations at Epstein's residences, meaning the information was obtainable through other means.
DOJ-OGR-00021023.jpg
This legal document is a court's analysis of a defendant's claim that missing evidence—such as financial records, phone records, and flight manifests—was prejudicial to her case. The court rejects this argument, stating the defendant failed to demonstrate what the absent documents would have shown or how they would have been beneficial, concluding the claims are purely speculative. The court notes that the missing evidence could just as easily have further substantiated the government's case.
DOJ-OGR-00021014.jpg
This legal document details a dispute between the Defendant and the Court regarding how to respond to a deliberating jury's note. The Defendant's initial proposed responses were deemed erroneous, and she later conceded a point about a return flight's potential connection to illegal sexual activity. The document outlines the Defendant's attempts to influence the jury's understanding through specific instructions and supplemental proposals.
DOJ-OGR-00021009.jpg
This legal document, part of a court filing, discusses limiting instructions given to a jury. The instructions clarified that the testimony of two witnesses, Kate and Annie, could not be the sole basis for conviction on certain counts because their experiences either involved someone not legally a victim under the specific charges (Kate) or occurred in a different jurisdiction (Annie in New Mexico). The court aimed to focus the jury's attention on the specific alleged crime: the transport of a minor, Jane, to New York for sexual activity illegal under New York law.
DOJ-OGR-00021008.jpg
This legal document, filed on April 29, 2022, discusses the jury instructions given in a criminal trial. It details how the Court instructed the jury that the Defendant's charges under the Mann Act were predicated on specific violations of New York Penal Law Section 130.55, which criminalizes sexual contact with a person under seventeen. The document confirms the Court clarified this point and specified overt acts from the indictment, including one from 1996, to guide the jury's deliberations.
DOJ-OGR-00021005.jpg
This document is page 22 of a court order (Document 657) filed on April 29, 2022, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The page outlines the 'Applicable Law' regarding the Fifth Amendment's Grand Jury Clause and 'prejudicial variance' or 'constructive amendment' of an indictment. It cites various legal precedents (Second Circuit cases) to define the standards for determining if a defendant was convicted of a crime different from the one charged in the indictment. The Court denies the Defendant's motion on this basis.
DOJ-OGR-00021004.jpg
This legal document is a court filing that denies a defendant's motions for acquittal and to vacate convictions related to the Mann Act. The court found sufficient evidence from witness testimonies (including from 'Carolyn', 'Annie', and 'Kate') to conclude that the defendant conspired with Epstein to transport minors to locations like New York, New Mexico, and the Caribbean for illegal sexual activity. The defendant's actions, such as paying for sexualized massages and inviting girls to travel, were considered part of this conspiracy, justifying the jury's conviction.
DOJ-OGR-00021003.jpg
This legal document, a page from a court filing dated April 29, 2022, outlines the court's conclusion that trial evidence supported a guilty verdict for the Defendant on Count Three, conspiracy to transport minors for illegal sexual activity. The document summarizes testimony from victims 'Jane' and 'Annie,' who described being groomed and taken on trips to New York and New Mexico by the Defendant and co-conspirator Epstein. The court found this and other evidence sufficient to prove the Defendant's guilt beyond a reasonable doubt.
DOJ-OGR-00021001.jpg
This legal document is a court's conclusion that sufficient evidence exists for a jury to find the Defendant guilty on counts of transporting a minor and sex trafficking. The conclusion is based on the testimony of a victim, "Jane," who stated the Defendant facilitated her travel with Jeffrey Epstein from Palm Beach to New York, assisted her in boarding flights, and was present during Epstein's sexual abuse of her when she was a minor.
DOJ-OGR-00020998.jpg
This legal document is a court filing that analyzes whether two criminal counts (Count Three and Count Five) are multiplicitous, meaning they charge the same crime. The court concludes that because the Government presented the case as a single, broad conspiracy involving the Defendant and Epstein, the counts are indeed multiplicitous. To avoid double jeopardy, the court rules that it will only impose judgment on one of the counts (Count Three).
DOJ-OGR-00020997.jpg
This document is a page from a legal ruling (likely the Maxwell case, 1:20-cr-00330) discussing legal arguments regarding conspiracy counts, overt acts, and the interdependence of crimes. It analyzes whether the abuse of specific victims (Carolyn, Jane, Annie) constituted one common conspiracy or distinct conspiracies involving the Defendant and Epstein. The text references legal precedents and the timing of the Trafficking Victims Protection Act enactment in 2000.
DOJ-OGR-00020996.jpg
This legal document details how the Defendant and Epstein used financial gifts and payments as a grooming tactic to gain victims' trust and facilitate sexual abuse. It cites testimony from a victim named 'Jane' about receiving money and payments for lessons, and mentions promises made to another victim, 'Annie'. The document also discusses the geographic scope of the conspiracy, noting that sexual conduct occurred not only in New York and Florida but also in New Mexico and London, involving other victims like Carolyn and Virginia Roberts.
DOJ-OGR-00020995.jpg
This legal document, dated February 28, 2023, discusses a 'pyramid scheme of abuse' involving a defendant and Jeffrey Epstein, spanning over a decade. It details how massage was used as a primary method to normalize contact, instigate sexual abuse, and lure young girls, with the defendant also providing cash. The text references trial testimony and legal precedents to argue the continuity and nature of the abuse scheme.
DOJ-OGR-00020990.jpg
This legal document analyzes two counts from an indictment against an unnamed Defendant. Count Three alleges a conspiracy from 1994-2004 to transport minors across state lines for sexual activity, based on testimony from victims Jane, Carolyn, and Annie Farmer. Count Five alleges a conspiracy from 2001-2004 for trafficking individuals for commercial sex acts, based on evidence related to Carolyn and Virginia Roberts. The Defendant argues, and the Court appears to agree, that Count Five is a subset of Count Three.
DOJ-OGR-00020971.jpg
This legal document, filed on April 1, 2022, discusses the jury selection process in a criminal case. It details how the Defendant chose not to challenge for cause two prospective jurors, Juror A and Juror B, despite their disclosures of personal experiences related to sexual abuse. The document contrasts their situations with that of another juror, Juror 50, and notes that all affirmed their ability to remain fair and impartial.
| 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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