DOJ OGR 00011205: Arrest Warrant Order for Kelly Bovino in the Ghislaine Maxwell Trial

PostedSeptember 19, 2026

UpdatedSeptember 19, 2026

ByEpsteinWiki

Snapshot

On December 17, 2021, United States District Judge Alison J. Nathan granted a request from Ghislaine Maxwell’s defense for an arrest warrant for Kelly Bovino. The one page order, released as DOJ OGR 00011205, directed the United States Marshals to arrest Bovino and bring her to the federal courthouse at 40 Foley Square in New York.

The order arose during Maxwell’s criminal trial. Her lawyers said Bovino had been personally served with a defense subpoena, had stopped responding, and possessed material testimony. The defense wanted her to deny participating in sexualized group massages described by a survivor who testified under the pseudonym Jane.

The surrounding record materially limits what can be inferred from the order. The subpoena commanded Bovino to appear on November 29, 2021, but the proof of service says it was served on November 30. Prosecutors opposed an arrest warrant, challenged the subpoena’s enforceability, disputed the importance of the proposed testimony, and argued that the defense had waited too long. Most importantly, the December 17 trial transcript records that Maxwell’s counsel later withdrew the application to have the Marshals arrest Bovino.

No reviewed record establishes that Bovino was arrested, detained, transported to New York, or called as a witness. The order proves that the judge authorized compulsory action at one point in the final days of the defense case. It does not prove that the warrant was executed.

Key Takeaways

DOJ OGR 00011205 is a one page federal court order dated December 17, 2021.
Judge Alison J. Nathan granted Maxwell’s request for an arrest warrant for Kelly Bovino.
The order directed the United States Marshals to arrest Bovino and bring her to the Southern District of New York.
Maxwell’s lawyers described Bovino as a material defense witness whose testimony would be relevant and exculpatory.
The defense intended to elicit a denial from Bovino concerning sexualized group massages described by Jane.
Prosecutors said Jane had previously identified Kelly Bovino to investigators, but they argued that the proposed denial would not properly contradict Jane’s trial testimony.
The subpoena listed an appearance date one day before the documented date of service.
Prosecutors raised that timing defect and urged the court not to issue the warrant.
The same day trial transcript records that Maxwell’s defense withdrew the arrest application.
Bovino did not testify in the completed defense case.
The released record does not show that the Marshals arrested or detained her.
The order contains no finding that Bovino committed a crime or participated in Epstein’s abuse.

Document Profile Chart

Field	Information
Evidence ID	DOJ OGR 00011205
Document type	Federal court order
Court	United States District Court for the Southern District of New York
Criminal case	United States v. Ghislaine Maxwell
Trial case number	20 Cr. 330 AJN
Judge	Alison J. Nathan
Order date	December 17, 2021
Subject	Defense request for an arrest warrant for Kelly Bovino
Direction	United States Marshals to arrest Bovino and bring her to 40 Foley Square
Length	One page
Later docket header	Document 702 attachment 4, filed July 12, 2022, under the PAE case suffix
Known execution status	No execution established in the reviewed record
Same day development	Defense withdrew the arrest application before closing its case

What the Order Says

The operative language is brief. The court states that Maxwell moved for an arrest warrant because Bovino had not complied with a subpoena to testify. The court grants the motion, orders that a warrant will issue, and directs the United States Marshals to arrest Bovino and bring her to the Thurgood Marshall United States Courthouse in Manhattan.

The order does not explain the expected testimony, describe efforts to contact Bovino, analyze the subpoena’s dates, or address the prosecution’s objections. Those facts appear in the motion, affidavit, exhibits, opposition, and trial transcript.

The released page also does not contain the arrest warrant itself. It is an order authorizing the warrant. That distinction matters because an authorization does not establish execution.

Evidence Chain Chart

Evidence	Date or role	What it contributes
DOJ OGR 00011201	Defense subpoena	Names “Kelly Bovino Umekubo” and commands an appearance on November 29, 2021
DOJ OGR 00011202	Proof of service	Records personal service on November 30, 2021, according to the defense filing and prosecution response
DOJ OGR 00011363	Defense evidentiary brief	Explains the testimony Maxwell’s lawyers expected from Bovino
DOJ OGR 00011253	Government motion	Seeks to limit testimony from Bovino and two other proposed witnesses
DOJ OGR 00011197	Defense warrant motion	Requests arrest and detention to compel Bovino’s testimony
DOJ OGR 00011203	Menninger affidavit	Calls Bovino a material witness and describes failed contact efforts
DOJ OGR 00011300	Government opposition	Challenges the subpoena timing, necessity, and lateness of the request
DOJ OGR 00011205	Court order	Grants the request and directs the Marshals to arrest Bovino
DOJ OGR 00016730	December 17 trial transcript	Records the live dispute, the court’s concerns, and the later withdrawal
DOJ OGR 00016908	Withdrawal page	Records counsel withdrawing the application to have Bovino arrested

How the Warrant Request Developed

The dispute unfolded during the last stage of Maxwell’s defense case.

Maxwell’s attorneys possessed government interview material concerning Jane by October 11, 2021. According to the defense, those materials identified a woman named Kelly whom Jane believed could support what she had told investigators about Maxwell. The defense later identified that person as Kelly Bovino.

The subpoena in DOJ OGR 00011201 uses the name “Kelly Bovino Umekubo.” It commands her to appear at 9:00 a.m. on November 29, 2021, the first day of trial. The defense said a process server personally served her on November 30.

The defense told the court that it tried to contact Bovino after service, attempted to place her on call as a witness, and received no response. On the morning of December 17, counsel raised the problem in court and said intervention by the Marshals appeared necessary. Judge Nathan directed the defense to file an application quickly because the trial would not be delayed.

The defense filed its warrant motion and an affidavit from attorney Laura Menninger. Prosecutors filed an opposition. Judge Nathan then signed the order granting the request.

Later that day, before the defense rested, the parties returned to court. The transcript records Judge Nathan confirming that the defense was withdrawing its request. Menninger answered that the application to have the Marshals arrest Bovino for nonappearance was withdrawn.

Procedural Timeline Chart

Date	Event	Evidence
October 11, 2021	Defense says it received interview material relevant to Bovino	DOJ OGR 00016730
November 2021	Subpoena issued by the clerk	DOJ OGR 00011201
November 29, 2021	Appearance date printed on subpoena	DOJ OGR 00011201
November 30, 2021	Defense says Bovino was personally served	DOJ OGR 00011202 and DOJ OGR 00011203
December 15, 2021	Government moves to restrict proposed testimony from Bovino and other witnesses	DOJ OGR 00011253
December 16, 2021	Defense argues Bovino should be allowed to testify	DOJ OGR 00011363
Morning of December 17, 2021	Defense tells court a subpoenaed witness is unresponsive	DOJ OGR 00016730
December 17, 2021	Defense files warrant motion and affidavit	DOJ OGR 00011197 and DOJ OGR 00011203
December 17, 2021	Government opposes the request	DOJ OGR 00011300
December 17, 2021	Judge grants request and directs Marshals to arrest Bovino	DOJ OGR 00011205
Later December 17, 2021	Defense withdraws arrest application and completes its case without Bovino	DOJ OGR 00016908
December 29, 2021	Jury finds Maxwell guilty on five counts	United States Attorney’s Office sentencing summary
July 12, 2022	Motion papers and order are filed publicly as docket attachments	Headers on Documents 702, 702 attachment 3, 702 attachment 4, 706, 713, and 723

Why Maxwell’s Defense Wanted Bovino

The warrant cannot be understood without Jane’s testimony and the competing descriptions of Bovino’s expected evidence.

Jane testified under a court approved pseudonym. On cross examination, Maxwell’s lawyers asked about people Jane had mentioned to investigators. The filings say Jane remembered a woman named Kelly, remembered Kelly’s last name, described her as an older model, and said Kelly could support what she had discussed regarding Maxwell.

The defense brief in DOJ OGR 00011363 says Jane had identified the woman to investigators as Kelly Bovino. Maxwell’s lawyers represented that Bovino would not support Jane’s account of sexualized group massages. They argued that this denial would contradict Jane and directly concern the conduct at issue in the case.

That was an advocacy position, not testimony from Bovino. Bovino did not take the stand, so the public trial record contains no sworn denial from her and no cross examination testing what the defense expected her to say.

The Government’s Position

Prosecutors took two related positions.

First, they sought to restrict the proposed testimony. In DOJ OGR 00011253, the government said Jane had previously told investigators that Kelly Bovino was involved in group sexualized encounters. Prosecutors nevertheless argued that a denial from Bovino would not properly contradict Jane’s testimony before the jury because the defense had not elicited Bovino’s full name or a firm identification during Jane’s trial testimony. They also argued that the issue concerned collateral adult sexual activity and could confuse the jury.

Second, prosecutors opposed the arrest request itself. Their filing in DOJ OGR 00011300 identified several objections:

The subpoena required an appearance on November 29 but was not served until November 30.
The defense had possessed the relevant interview material since October.
The defense waited until the expected final day of its case to alert the court.
Bovino was believed to be in California, making arrest and transport likely to delay the trial.
Prosecutors considered the proposed testimony cumulative of testimony sought from two other witnesses.
The trial was proceeding during the pandemic and before holiday breaks.

The court granted the warrant request despite that opposition. The released one page order does not explain how Judge Nathan resolved each objection.

The Subpoena Date Problem

The most visible procedural defect is contained in the defense’s own exhibits.

Subpoena field	Recorded date
Required court appearance	November 29, 2021 at 9:00 a.m.
Personal service	November 30, 2021
Difference	Service occurred one day after the commanded appearance

The government argued that Bovino could not have disobeyed a command before receiving it. Its opposition therefore questioned whether she was validly under subpoena for purposes of the requested arrest.

The defense described later efforts to contact her and represented that she would not appear. The judge still granted the application. The order does not say whether the court treated the date mismatch as a clerical error, relied on later communications, or accepted another legal basis for compulsion.

This is not a minor archival detail. It limits any claim that the order itself proves a straightforward refusal to obey a valid command on November 29.

The Statutory Citation Problem

The motion invoked several possible sources of authority, including the court’s inherent authority, contempt power, the recalcitrant witness statute, and the federal material witness statute.

The defense letter correctly identifies the material witness provision as 18 U.S.C. § 3144. Menninger’s attached affidavit, however, is captioned as an affidavit under 28 U.S.C. § 3144 and repeats that citation in its final paragraph. Title 28 does not contain the material witness statute invoked by the motion. The operative provision is in Title 18.

The order does not cite either statute. It simply grants the motion. The mismatch should be recorded as a drafting error in the supporting affidavit, not silently corrected in a quotation or treated as evidence of a different legal authority.

What the Same Day Withdrawal Changes

The withdrawal is the most important limitation on the one page order.

At transcript page 2720, released as DOJ OGR 00016908, Judge Nathan asks whether the application concerning “the witness Kelly” has been withdrawn. Menninger confirms that it has. When the judge asks for precision, counsel identifies it as the application to have the Marshals arrest Kelly Bovino for nonappearance under the subpoena.

The transcript then moves to the parties’ agreement to complete the evidence without further defense witnesses or a government rebuttal case. Maxwell declined to testify. Bovino did not appear as a witness.

The available documents do not state whether a warrant was formally entered into a law enforcement database before withdrawal, whether it was immediately cancelled, or whether the signed order was ever transmitted for execution. They do show that the party seeking enforcement withdrew the request before the defense case ended.

For that reason, the most accurate formulation is that Judge Nathan authorized a warrant, after which Maxwell’s defense withdrew its arrest application. It is not accurate to say the evidence proves that Bovino was arrested.

Order, Warrant, Arrest, and Testimony Chart

Proposition	Status	Evidentiary basis
Defense asked for Bovino’s arrest	Confirmed	DOJ OGR 00011197
Judge granted the request	Confirmed	DOJ OGR 00011205
Judge directed the Marshals to arrest Bovino	Confirmed	DOJ OGR 00011205
A separate warrant form was publicly released with this set	Not identified	The reviewed sequence includes the order but not a separate executed warrant
Marshals located Bovino	Not established	No reviewed return or transcript entry confirms it
Bovino was arrested	Not established	No reviewed arrest record or testimony confirms it
Bovino was transported to New York	Not established	No reviewed record confirms transport
Bovino testified	No	Defense completed its case without her
Defense withdrew the arrest application	Confirmed	DOJ OGR 00016908

Docket and Release Provenance

The order presents two layers of case information.

Its embedded caption uses 20 Cr. 330 AJN, the initials of Judge Alison J. Nathan, who presided over the trial and dated the order December 17, 2021. The later electronic header identifies it as Document 702 attachment 4, filed July 12, 2022, under a PAE suffix.

This means the public filing date is not the date the order was made. The order belongs to the December 2021 trial record and was later attached to a July 2022 docket filing. Researchers should not date the ruling to July 2022 or attribute it to the judge whose initials appear only in the later docket header.

The printed evidence stamp is DOJ OGR 00011205. OGR refers to the Department of Justice Office of Government Relations production prefix used for this release. Epstein Data describes DOJ OGR as a House Oversight and Justice Department document group, distinct from the EFTA numbered production.

Evidentiary Significance

The order is significant for three reasons.

First, it confirms that Maxwell’s defense considered Bovino important enough to seek federal arrest authority during trial. The defense linked her expected testimony to statements by Jane and characterized it as exculpatory.

Second, the surrounding filings preserve a contested identification. The government said Jane had named Kelly Bovino in an earlier interview. The defense intended to call Bovino to deny the conduct. Because Bovino did not testify, the jury did not hear or evaluate that proposed denial.

Third, the record shows how quickly an extraordinary trial request can change. The signed order appears definitive when read alone. The same day transcript shows that the request was later withdrawn. Reading the order without the transcript produces an incomplete and potentially misleading account.

The record should therefore be used to document process, not to manufacture conclusions about guilt, complicity, or arrest.

Survivor Centered Reading

Jane’s account concerned sexual abuse and exploitation. The government and defense filings discuss her credibility in adversarial terms because they were litigating what evidence the jury could hear. Their arguments are not neutral factual summaries.

The defense’s representation that Bovino would deny participation does not itself disprove Jane’s account. A proposed witness denial is not evidence until the witness testifies under oath and can be questioned. That never occurred here.

The government’s statement that Jane identified Bovino in an interview is also not a judicial finding that Bovino participated in abuse. The order addresses compulsory attendance, not the truth of the underlying allegation.

Maxwell was convicted on December 29, 2021, after Bovino did not testify. In June 2022, Judge Nathan sentenced Maxwell to 20 years in prison for her role in a scheme with Jeffrey Epstein to sexually exploit and abuse minor girls.

What the Evidence Establishes

Kelly Bovino Umekubo was named in a defense trial subpoena.
The subpoena printed an appearance date of November 29, 2021.
The defense represented that personal service occurred on November 30, 2021.
Maxwell’s lawyers said Bovino stopped responding and did not appear.
The defense described her as a material witness with relevant and exculpatory testimony.
The defense expected Bovino to deny participating in sexualized group massages described by Jane.
The government said Jane had previously identified Kelly Bovino during an interview.
Prosecutors opposed both the proposed testimony and the arrest request.
Judge Nathan granted the warrant request on December 17, 2021.
The defense later withdrew the application to have the Marshals arrest Bovino.
The defense completed its case without Bovino’s testimony.

What the Evidence Does Not Establish

That Bovino was arrested.
That a warrant was executed.
That Bovino was detained or transported to New York.
Why Bovino did not respond to the defense.
Whether Bovino received a corrected subpoena after the November date mismatch.
Whether Bovino intended to invoke a constitutional privilege.
What Bovino would actually have said under oath.
That the court accepted the defense’s description of her proposed testimony as true.
That the court found Jane’s account unreliable.
That the court found Bovino participated in abuse.
That the warrant order was a criminal charge or conviction against Bovino.

Questions for Further Investigation

Was a separate arrest warrant prepared or entered after the order was signed?
Did the court formally cancel or vacate any warrant after the defense withdrew its application?
Is there a Marshals Service return showing attempted or completed execution?
Did Bovino or an attorney communicate with the court, prosecutors, or defense after December 17?
Was a corrected subpoena ever issued with a valid future appearance date?
What precise contact efforts did the defense make after November 30?
Why did the defense withdraw the application after obtaining the order?
Did the parties reach a stipulation that made Bovino’s appearance unnecessary?
Are there sealed docket entries that clarify the withdrawal or warrant status?
Is the separate warrant preserved in the complete court file or Marshals records?
What original interview reports support the competing descriptions of Jane’s statements?
Why does the Menninger affidavit cite 28 U.S.C. § 3144 instead of 18 U.S.C. § 3144?
Was the November 29 appearance date a clerical mistake, and did Bovino understand a later appearance was demanded?

Related Evidence

Sources

DOJ-OGR-00011205 Download

Tags:

Court Filings, Orders, Rulings