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-00021136.jpg
This legal document, dated February 28, 2023, discusses the conviction of Maxwell on Count Four, which was based on Jane's testimony about sexual activity with Epstein in New Mexico. It argues that the Court's failure to address the jury's misunderstanding, as revealed by a 'Jury Note' concerning the transportation count, warrants vacating Maxwell's convictions on Counts Three and Four and granting a new trial. The document highlights the distinction between the original indictment and the basis for conviction, implicitly linking the 'defendant' in the jury note to Maxwell.
DOJ-OGR-00021130.jpg
This legal document, part of case 22-1426, argues that the District Court abused its discretion during a post-trial hearing. The filing contends that the court improperly prevented the defense from cross-examining Juror 50, who, it is argued, would have been dismissed from the jury had he truthfully disclosed the nature of his past abuse during jury selection. The document contrasts the severe abuse suffered by Juror 50 with lesser forms of sexual assault reported by other potential jurors who were not dismissed.
DOJ-OGR-00021111.jpg
This page from a legal brief (dated Feb 28, 2023) argues that the District Court erroneously relied on the non-controlling case *Weingarten v. U.S.* regarding the statute of limitations (specifically § 3283 vs § 3282) and Mann Act violations. The text analyzes the legislative history of the 2003 amendment to argue that the statute was intended for cases involving the actual abduction and rape of a child, distinguishing it from crimes that do not categorically involve minor abuse.
DOJ-OGR-00019560.jpg
This legal document is a court ruling denying a Defendant's request to modify a protective order in a criminal case. The Court found the Defendant's arguments for disclosing materials to judicial officers in other civil proceedings to be vague and lacking good cause. The information the Defendant sought to disclose, related to a grand jury investigation into Jeffrey Epstein, was deemed already publicly available.
DOJ-OGR-00019559.jpg
This document is page 2 of a court order filed on August 2, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The court denies the Defendant's request to modify a protective order, reaffirming that discovery materials produced by the Government must be used solely for the defense of the criminal action and not for any civil proceedings. The text cites Federal Rule of Criminal Procedure 16(d)(1) and various legal precedents regarding 'good cause' for protective orders.
DOJ-OGR-00019550.jpg
This document is a page from a government filing addressed to Judge Alison J. Nathan, arguing against a defense request to use criminal discovery materials in civil cases. The text details the background of grand jury subpoenas related to the Jeffrey Epstein investigation, the modification of protective orders to allow compliance, and asserts that using these materials for civil litigation violates the protective order in the current criminal case.
DOJ-OGR-00019544.jpg
This legal document, filed on July 30, 2020, details the post-case responsibilities of the Defense Counsel. It mandates that all discovery materials provided by the Government must be returned or securely destroyed within 30 days after the case's final conclusion and all appeal periods have passed. The document also stipulates that the Government and Defense Counsel must meet before any hearings or trials to agree on how evidence will be presented.
DOJ-OGR-00019543.jpg
This document is page 10 of a legal order, likely a protective order, filed on July 30, 2020. It details strict rules for the Defendant and their legal team regarding the handling of confidential discovery materials, prohibiting dissemination, copying, and public filing without explicit authorization from the Government or the Court. The order specifies that materials must be reviewed in the presence of counsel and may be inspected under the protection of law enforcement.
DOJ-OGR-00019541.jpg
This document is page 8 of a Protective Order filed on August 20, 2020, in Case 1:20-cr-00330-AJN (U.S. v. Ghislaine Maxwell). It outlines strict protocols for the Defendant's review of discovery materials, mandating supervision by Defense Counsel or BOP officials, and establishes rules for handling 'Highly Confidential Information' produced by the Government.
DOJ-OGR-00019540.jpg
This is page 7 of a court order (Document 30, filed July 2, 2020) in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The text outlines strict protocols for handling 'Confidential Information,' specifically prohibiting the use of such materials for civil proceedings and restricting the Defendant from possessing hard copies unless in the presence of Defense Counsel. It also establishes that the Bureau of Prisons (BOP) will facilitate electronic access to discovery materials for the defendant.
DOJ-OGR-00019538.jpg
This document is page 5 of a court order filed on July 30, 2020, for case 1:20-gp-00330-AJN. The order prohibits the defense team (including the Defendant, Counsel, Staff, Experts, and Witnesses) from publicly disclosing or filing the identities of victims or witnesses referenced in the Discovery process. An exception is made for individuals who have already spoken on the public record, or if the disclosure is authorized in writing by the Government or by an order from the Court, in which case the filing must be made under seal.
DOJ-OGR-00019536.jpg
This page is part of a legal order filed on July 30, 2020, that governs the handling of discovery materials in a court case. It specifies which third parties—such as defense staff, experts, and potential witnesses—are permitted to receive these materials from the defendant's counsel for trial preparation. The document mandates that any such 'Designated Person' must first sign a copy of the order, formally agreeing to its terms, before being granted access to the materials.
DOJ-OGR-00019535.jpg
This document is page 2 of a court order filed on July 30, 2020, related to a criminal case. The order establishes strict rules for how the defendant and their legal team ('Defense Counsel') can handle discovery materials provided by the Government. It specifies that the materials must be used solely for the defense in this criminal action, restricts copying and distribution, and lists the specific types of personnel ('Designated Persons') who are authorized to view the information.
DOJ-OGR-00019532.jpg
This document is page 11 of a court order (likely a Protective Order) from the case United States v. Ghislaine Maxwell (1:20-cr-00330). It outlines the strict protocols for the Defense Counsel regarding the handling, return, or destruction of 'Discovery' and 'Confidential Information' provided by the Government. It stipulates that materials must be destroyed or returned within 30 days of the finalization of the case (including appeals) and mandates that both parties meet to discuss evidence presentation before trials.
DOJ-OGR-00019529.jpg
This document is page 8 of a legal filing (Protective Order) from Case 1:20-cr-00330 (USA v. Ghislaine Maxwell), filed on July 28, 2020. It outlines strict protocols for the handling of 'Highly Confidential Information' during the discovery process, specifically dictating that the Defendant may only review materials in the presence of counsel or via BOP officials, and establishing rules for showing materials to potential defense witnesses without providing them copies.
DOJ-OGR-00019528.jpg
This page from a legal document, filed on July 28, 2020, details the strict protocols for handling Confidential Information in a criminal case. It stipulates that such information can only be used for the defense of the current action, must be kept secure, and outlines specific rules for how the defendant can access it in hard copy (only with counsel present) and electronically (facilitated by the Bureau of Prisons). The Government's designation of information as confidential is binding unless overridden by a court order.
DOJ-OGR-00019524.jpg
This document is a page from a legal order filed on July 28, 2020, detailing who is permitted to access discovery materials in a criminal case. It specifies that defense staff, experts, court-authorized individuals, and potential witnesses can receive these materials under strict conditions. The order requires any designated person receiving the materials to first sign a copy, agreeing to be bound by its terms, to ensure confidentiality during trial preparation.
DOJ-OGR-00019523.jpg
Page 2 of a Protective Order filed on July 28, 2020, in Case 1:20-cr-00330-AJN (USA v. Ghislaine Maxwell). The document outlines strict protocols for handling discovery materials, mandating they be used solely for criminal defense purposes and prohibiting the defendant from copying or distributing them to anyone other than counsel. It defines 'Designated Persons' (support staff) who are permitted to view the materials.
DOJ-OGR-00019511.jpg
This page is from a legal document filed on July 27, 2020, outlining the rules for handling "Highly Confidential Information" in a criminal case (Case 1:20-cr-00330-AJN). It specifies that such information may include sexualized images and details the legal process for Defense Counsel to challenge this designation with the Government and the Court. The document also strictly limits the use of this information to the defense of the criminal action and prohibits its further dissemination.
DOJ-OGR-00019510.jpg
This document is page 9 of a protective order filed on July 27, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). It establishes strict protocols for the handling of discovery materials, stating that the Defendant may only review them in the presence of counsel or via BOP officials. It further defines 'Highly Confidential Information' and restricts Potential Defense Witnesses to viewing materials via read-only platforms without receiving physical copies.
DOJ-OGR-00019509.jpg
This document is page 7 (filed as page 8 of 13) of a protective order in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It stipulates strict handling procedures for 'Confidential Information,' limiting its use solely to the criminal defense and prohibiting use in civil proceedings. It specifically mandates that the defendant may only review hard copies in the presence of counsel and that electronic access within the Bureau of Prisons must be facilitated by BOP officials.
DOJ-OGR-00019505.jpg
This document is page 4 of a Protective Order filed on July 2, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It defines categories of individuals permitted to access discovery materials, including 'Defense Experts/Advisors' and 'Potential Defense Witnesses.' It mandates that any 'Designated Persons' receiving such materials must sign an agreement to be bound by the terms of the Order, which Defense Counsel must retain for potential court review.
DOJ-OGR-00019504.jpg
This document is a court order, filed on July 27, 2020, that sets forth the rules for handling discovery materials in a criminal case. It strictly limits the use of these materials by the defendant and her defense counsel to the defense of the current criminal action. The order prohibits unauthorized copying, transmission, and distribution, specifying that disclosure is only permitted to a defined group of "Designated Persons," such as the defense team's investigative and paralegal staff.
DOJ-OGR-00019444.jpg
This document is the final signature page (page 5) of a court order filed on September 2, 2020, in Case 1:20-cr-00330 (United States v. Ghislaine Maxwell). United States District Judge Alison J. Nathan orders that the Defendant may make unsealing applications to other courts if she wishes. The document bears the Bates stamp DOJ-OGR-00019444.
DOJ-OGR-00019443.jpg
This legal document, part of a court filing from March 2, 2020, outlines a procedural history involving civil protective orders in a criminal case. In 2019, the Government successfully modified a protective order in one court (Court-1) to obtain materials from a 'Recipient' for a grand jury, while another court (Court-2) denied a similar request. The current court is now permitting the Defendant, who learned of this through discovery, to provide this sealed information to Court-1 and Court-2 so those courts can determine whether to unseal related materials.
| 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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