Maxwell v. Estate of Jeffrey Epstein, No. ST-20-CV-155
Snapshot
| Field | Information |
|---|---|
| Case name | Ghislaine Maxwell v. Estate of Jeffrey E. Epstein, et al. |
| Case number | ST-20-CV-155, also displayed as ST-2020-CV-00155 |
| Court | Superior Court of the Virgin Islands |
| Division | St. Thomas and St. John |
| Filing date | March 12, 2020 |
| Plaintiff | Ghislaine Maxwell |
| Defendants | Estate of Jeffrey E. Epstein, Darren K. Indyke as executor, Richard D. Kahn as executor, and NES, LLC |
| Type of action | Civil action seeking indemnification and advancement of expenses |
| Principal expenses requested | Attorneys’ fees, personal security, safe accommodation, litigation expenses, and related future costs |
| Causes of action | Promissory estoppel and contractual indemnification, common law indemnification, and indemnification through NES, LLC and other Epstein entities |
| Filing length | 10 pages |
| Primary EFTA range | EFTA01306528 through EFTA01306537 |
| Duplicate EFTA range | EFTA00196891 through EFTA00196900 |
| SDNY discovery range | SDNY_GM_00324057 through SDNY_GM_00324066 |
| Procedural status | Defendants later sought dismissal for failure to prosecute and on public policy grounds. A publicly circulated proposed dismissal order is undated and should not be treated as an entered final judgment without docket confirmation |
On March 12, 2020, Ghislaine Maxwell sued the Estate of Jeffrey Epstein, its executors Darren Indyke and Richard Kahn, and Epstein controlled company NES, LLC.
Maxwell asked the Virgin Islands court to require the defendants to pay legal fees, security expenses, safe housing costs, and other expenses she claimed arose from her employment by Epstein and his affiliated businesses.
The complaint is significant because Maxwell expressly characterized herself as Epstein’s employee and property manager. She alleged that she worked for Epstein and several of his companies from approximately 1999 through at least 2006 and managed properties in New York, Paris, Florida, New Mexico, and the United States Virgin Islands.
The filing also claimed that Maxwell had no involvement in or knowledge of Epstein’s alleged misconduct. That assertion was made before her July 2020 arrest and before a federal jury convicted her in December 2021 of offenses connected to Epstein’s sexual abuse of minors.
Nature of the Lawsuit
This case was a civil financial dispute. It was not Maxwell’s federal criminal prosecution, an appeal from her criminal conviction, or a survivor compensation claim.
Maxwell sought two related forms of financial protection.
Indemnification generally means reimbursement for expenses, losses, or liabilities incurred because of a covered relationship or activity.
Advancement generally means payment of legal expenses while litigation or an investigation is still pending, before ultimate liability has been determined.
Maxwell wanted the Epstein estate and related entities to pay expenses she had already incurred and expenses she expected to incur in the future.
Her complaint requested coverage for threatened, pending, or completed lawsuits, proceedings, and investigations connected to Epstein, his businesses, and his alleged victims.
Parties
Ghislaine Maxwell
Maxwell filed the lawsuit as plaintiff. The complaint described her as an adult citizen of the United States.
At the time of filing, Maxwell had not yet been arrested on federal charges. Her location was the subject of substantial public and law enforcement interest.
Estate of Jeffrey E. Epstein
The Estate of Jeffrey Epstein was created following Epstein’s death on August 10, 2019. The complaint alleged that the estate was domiciled in the United States Virgin Islands.
Darren Indyke
Darren Indyke was sued in his official capacity as an executor of the estate.
Maxwell alleged that Indyke had assured her that Epstein’s promises would be honored and that her legal fees and obligations would be reimbursed.
Richard Kahn
Richard Kahn was sued in his official capacity as the other executor of the estate.
The complaint also alleged that Kahn had served as comptroller of NES, LLC by September 2006.
NES, LLC
NES, LLC was described as a New York limited liability company organized on or about August 13, 1998.
Maxwell alleged that she had been employed as a manager by NES and that its organizational documents likely entitled her to mandatory indemnification and advancement.
Jurisdiction
The complaint invoked the jurisdiction of the Superior Court of the Virgin Islands under 4 V.I.C. § 76.
It also alleged that venue was proper in the St. Thomas and St. John Division under 4 V.I.C. § 78 because Epstein’s estate was domiciled in the Virgin Islands and related property was located there.
The case was connected to the probate administration of Epstein’s estate, which was being overseen in the Virgin Islands.
Maxwell’s Claimed Employment History
The complaint alleged that Maxwell was employed by Epstein individually and by several of his affiliated businesses from approximately 1999 through at least 2006.
The companies named in the complaint included:
| Entity | Alleged relationship |
|---|---|
| NES, LLC | Maxwell alleged that she worked as a manager |
| C.O.U.Q. Foundation | Listed as an Epstein entity that employed Maxwell |
| New York Strategy Group | Listed as an affiliated employer |
| JEGE LLC | Listed as an affiliated employer |
| JEGE Inc. | Listed as an affiliated employer |
| LSJ, LLC | Listed as an affiliated employer connected to Epstein’s Virgin Islands property |
This allegation is important because Maxwell publicly attempted at different times to describe herself as Epstein’s girlfriend, former girlfriend, employee, property manager, or associate.
The complaint provides her own formal legal assertion that she worked for Epstein and a network of his entities.
Property Management Role
Maxwell alleged that she was responsible for managing Epstein’s properties in:
| Location | Related Epstein property |
|---|---|
| New York | Epstein’s Manhattan residences and related properties |
| Paris | Epstein’s Avenue Foch residence |
| Florida | Epstein’s Palm Beach residence |
| New Mexico | Zorro Ranch |
| United States Virgin Islands | Little St. James and related island entities |
This claimed management role overlapped with locations where survivors reported recruitment, grooming, sexual abuse, trafficking, and coercive control.
The complaint did not describe Maxwell’s daily duties at each property. It used the management relationship to support her argument that expenses arising from litigation and investigations should be treated as employment related costs.
Alleged Promises of Financial Support
Maxwell alleged that Epstein repeatedly promised to support her financially.
According to the complaint, the promises were made both in writing and in conversation. Maxwell claimed that Epstein repeated them while she was considering leaving his employment to start a business.
She alleged that Epstein assured her that he would continue supporting her even if her business ventures failed.
The complaint stated that Maxwell began transitioning to a more limited employment role around 2001.
It further alleged that in approximately 2004, she received a typed letter from Epstein containing a handwritten note. According to Maxwell, the note asked her to remain in Epstein’s employ and promised that he would continue supporting her regardless of what she decided to do.
The alleged letter was not attached to the ten page complaint.
Previous Payment of Maxwell’s Legal Expenses
Maxwell relied on Epstein’s prior conduct as evidence that his promises were real.
She alleged that Epstein had previously paid or advanced legal fees and settlement expenses for her in connection with civil litigation.
The complaint referenced a 2017 action identified as Jane Doe 43 v. Epstein, et al., No. 17-CV-00616-JGK.
It also referenced a civil case filed against Epstein in 2009. The name associated with that case is redacted in the released complaint.
Maxwell further alleged that Epstein had paid legal fees and expenses for other employees involved in litigation connected to him, his businesses, and alleged victims.
These allegations were intended to show a pattern of Epstein financially protecting employees and associates confronted with legal claims arising from his operation.
The complaint did not attach payment records, invoices, indemnification agreements, settlement documents, or the alleged 2004 letter.
Alleged Assurances From Darren Indyke
Maxwell claimed that Indyke personally assured her that her legal fees and obligations would be reimbursed by Epstein and the estate.
She alleged that Indyke told her that she would not have incurred the expenses but for Epstein’s alleged misconduct. According to Maxwell, Indyke said Epstein’s promises would be honored and her expenses would be paid going forward.
These were allegations made by Maxwell. The complaint did not attach correspondence from Indyke confirming the alleged assurances.
Indyke’s alleged statements became part of Maxwell’s promissory estoppel and contractual indemnification theory.
The November 22, 2019 Claim
Maxwell alleged that she submitted a written claim to the estate on November 22, 2019.
The claim was addressed to Indyke and Kahn. She asked the estate to honor what she described as Epstein’s obligation to indemnify her and advance her expenses.
The same letter allegedly requested copies of documents defining any indemnification or advancement rights available through NES, LLC and other Epstein entities.
Maxwell claimed that the estate did not honor or formally respond to her demand before she filed the lawsuit.
Contemporary reporting indicated that a Colorado law firm representing Maxwell in civil litigation had submitted a claim exceeding $600,000. The ten page complaint itself does not specify a fixed dollar amount.
Legal Fees, Security, and Safe Accommodation
The complaint sought more than reimbursement for attorneys.
Maxwell alleged that she had received regular threats to her life and safety following Epstein’s death. She said those threats required her to hire personal security and locate safe accommodation.
She described the costs as substantial, continuing, and connected to worldwide attention surrounding Epstein’s alleged misconduct.
The expenses sought included:
| Expense category | Description |
|---|---|
| Attorneys’ fees | Fees incurred in lawsuits, proceedings, and investigations |
| Personal security | Protection Maxwell claimed was required because of threats |
| Safe accommodation | Costs associated with finding secure housing |
| Litigation expenses | Other costs connected to legal proceedings |
| Future expenses | Costs expected to continue after the complaint |
| Fees for this lawsuit | Costs incurred while attempting to enforce the alleged indemnification promise |
| Interest | Prejudgment and postjudgment interest |
The complaint did not itemize the expenses or identify the total amount sought.
Count One: Promissory Estoppel and Contractual Indemnification
Count One alleged promissory estoppel and contractual indemnification.
Maxwell claimed that Epstein made clear promises to indemnify her and advance expenses associated with her employment relationship.
She alleged that she reasonably relied on those promises when she reduced or ended her employment and pursued independent business ventures.
According to Maxwell, the estate’s failure to honor those promises caused her financial harm.
The complaint asked the court to enforce the alleged promises against Epstein’s estate.
A central evidentiary issue was whether the alleged promises were sufficiently definite, whether they covered the conduct and proceedings at issue, and whether they remained enforceable after Epstein’s death.
Count Two: Common Law Indemnification
Count Two sought indemnification under common law.
Maxwell alleged that her employment relationship with Epstein created a legal and special relationship requiring the estate to reimburse her.
Paragraph 41 made one of the complaint’s most consequential assertions. Maxwell claimed she had no involvement in or knowledge of Epstein’s alleged misconduct.
Paragraph 42 asserted that the lawsuits, investigations, and proceedings involving her existed solely because she had been Epstein’s employee.
Those statements were allegations made in March 2020. They were not findings by the Virgin Islands court.
The theory became substantially more difficult after Maxwell’s federal criminal trial. A jury later found that she personally participated in criminal conduct connected to Epstein’s abuse of minors. The sentencing court also rejected her effort to portray herself as being punished merely for Epstein’s actions.
Count Three: NES, LLC and Other Epstein Entities
Count Three asserted indemnification rights through NES, LLC and other Epstein controlled entities.
Maxwell alleged that she worked as a manager for NES. She claimed that the company’s organizational documents likely contained mandatory indemnification and advancement provisions.
The complaint acknowledged that Maxwell had requested the relevant operating agreements and policies but had not received them.
She made similar allegations about the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC, JEGE Inc., and LSJ, LLC.
The wording “upon information and belief” is important. It indicates that Maxwell was alleging the probable existence of indemnification provisions without attaching the underlying corporate documents.
Relief Requested
Maxwell asked the court to enter judgment against the estate and NES, LLC.
The requested relief included:
| Requested relief | Meaning |
|---|---|
| Declaration of indemnification rights | A ruling that the estate or NES had to reimburse covered expenses |
| Advancement of expenses | Payment of current and future expenses while proceedings continued |
| Legal fees | Reimbursement for attorneys involved in lawsuits and investigations |
| Security costs | Payment for personal security |
| Safe housing costs | Reimbursement for secure accommodation |
| Fees from this action | Payment of the cost of suing the estate |
| Prejudgment interest | Interest accruing before judgment |
| Postjudgment interest | Interest accruing after judgment |
| Additional equitable relief | Any further remedy the court considered appropriate |
No precise damages amount appears in the complaint.
Survivor Response
The lawsuit immediately drew criticism from survivors and their attorneys because Maxwell sought payment from the same estate being pursued for survivor compensation.
ABC News reported that survivor attorney Sigrid McCawley condemned the attempt to take estate funds that could otherwise satisfy survivor claims.
Attorney Brad Edwards argued that Maxwell should answer questions about her full relationship with Epstein rather than seek funds from his estate.
Virginia Giuffre publicly responded by condemning Maxwell’s attempt to portray herself as a victim while seeking access to Epstein’s assets.
This survivor response provides essential context. At the time, more than 30 alleged victims had reportedly filed claims against the estate, and the Virgin Islands government was litigating over Epstein’s assets and the operation of a survivor compensation program.
Timing Before Maxwell’s Arrest
The filing date is important.
Maxwell filed the complaint on March 12, 2020. Federal authorities arrested her on July 2, 2020.
When the complaint was filed, Maxwell was under intense public scrutiny but had not yet been convicted or even arrested in the federal criminal case.
Her assertion that she had no involvement in or knowledge of Epstein’s misconduct must be understood as a prearrest litigation position.
The complaint also demonstrates that Maxwell had access to lawyers and was actively using the Virgin Islands court system during a period when her whereabouts were widely described as unknown.
Federal Conviction and Its Effect on the Civil Claims
On December 29, 2021, a federal jury convicted Maxwell of multiple offenses related to Epstein’s sexual exploitation of minors.
She was sentenced in June 2022 to 20 years in federal prison.
The conviction did not automatically decide every contractual question in the Virgin Islands indemnification case. It did, however, undermine two core factual assertions in her complaint:
| March 2020 allegation | Later criminal finding |
|---|---|
| Maxwell had no involvement in Epstein’s alleged misconduct | A federal jury found that Maxwell personally participated in criminal conduct |
| Proceedings existed solely because she had been Epstein’s employee | The criminal judgment was based on Maxwell’s own conduct, not employment status alone |
The later defense filings argued that requiring the estate or its entities to indemnify Maxwell for intentional criminal conduct would violate public policy.
The federal conviction and appellate history are documented in EFTA00156400.
Procedural History
| Date | Event |
|---|---|
| March 12, 2020 | Maxwell files the complaint |
| May 1, 2020 | The estate and NES move to dismiss |
| June 1, 2020 | The parties jointly request a temporary stay |
| June 2020 | The court grants the stay and sets September 7, 2020 as a response deadline |
| July 13, 2020 | The Virgin Islands Attorney General files a motion to intervene with two exhibits |
| September 8, 2020 | The initial stay expires or is lifted |
| September 11, 2020 | The estate formally rejects Maxwell’s indemnification claim, according to later defense filings |
| December 29, 2021 | Federal jury convicts Maxwell |
| July 1, 2022 | Virgin Islands court requests briefing on whether indemnification is barred by public policy |
| September 7, 2022 | Maxwell’s counsel is permitted to withdraw, and Maxwell is ordered to obtain new counsel |
| March 17, 2023 | Court holds a status conference and again directs Maxwell to obtain counsel |
| September 2023 | Defendants move to dismiss for failure to prosecute or compel Maxwell to appear without counsel |
| December 22, 2023 | Maxwell submits a response to the dismissal request |
| January 2024 | Defendants continue seeking dismissal |
| Later record | An undated proposed order states that the motion should be granted and the complaint dismissed |
Initial Motion to Dismiss
The estate and NES moved to dismiss the complaint on May 1, 2020.
According to later filings, the defendants argued that Maxwell’s estate claim was premature under 15 V.I.C. § 606(a). That provision generally restricts actions against executors during the first year following the issuance of letters testamentary.
Indyke and Kahn reportedly received letters testamentary on September 6, 2019. The parties therefore requested a stay until September 7, 2020.
The defendants also argued that Maxwell’s indemnification claims were barred by provisions of the 2014 NES operating agreement.
The attached complaint does not include the operating agreement or the defendants’ motion.
Virgin Islands Motion to Intervene
The Virgin Islands court’s public document collection lists a July 13, 2020 motion to intervene and two large supporting exhibits.
The motion was filed while the Virgin Islands government was pursuing its own claims against Epstein’s estate and attempting to preserve assets for survivors and other lawful claims.
The existence of the intervention request is confirmed by the public court index. Its precise arguments should be taken from the motion itself rather than inferred from the complaint.
Counsel Withdrawal and Failure to Prosecute
Maxwell’s attorneys from Quintairos, Prieto, Wood & Boyer later withdrew from the case.
The court reportedly ordered Maxwell to obtain replacement counsel within 60 days. She did not do so within the original period.
At a March 17, 2023 status conference, Maxwell appeared without counsel and was again directed to obtain representation.
The estate and NES later moved to dismiss the case under Virgin Islands Rule of Civil Procedure 41(b), arguing that Maxwell had failed to prosecute her own lawsuit and had disregarded court orders.
They alternatively asked the court to compel her to proceed without counsel so the unresolved dismissal motion could be decided.
Public Policy Argument
After Maxwell’s federal conviction, the defendants argued that indemnification would violate public policy.
Their position was that a person convicted of intentional criminal acts should not be permitted to shift the financial consequences of defending that conduct to another person, company, or estate.
This argument distinguished ordinary employment related litigation from criminal responsibility based on Maxwell’s personal conduct.
The indemnification question therefore became more than a dispute about whether Epstein promised to pay her bills. It raised the issue of whether such a promise could legally be enforced when the expenses were connected to intentional crimes for which Maxwell had been convicted.
Status Caution
A one page document circulating with the later case materials states that the defendants’ motion is granted and that Maxwell’s complaint is dismissed.
However, the available copy contains an undated signature area and resembles a proposed order submitted for judicial approval.
The provided complaint does not establish the final disposition, and the older public Virgin Islands document collection does not include the complete later docket.
Until an entered, dated, and signed dismissal order is confirmed through the official docket, the most accurate status description is:
Defendants sought dismissal for failure to prosecute and on substantive public policy grounds. A proposed dismissal order appears in the public record, but entry of a final dismissal should be verified against the official court docket.
Corporate Network Revealed by the Complaint
The lawsuit is valuable beyond the indemnification dispute because it records Maxwell’s claimed employment across several Epstein entities.
| Entity | Investigative importance |
|---|---|
| NES, LLC | Corporate employer and alleged source of indemnification rights |
| C.O.U.Q. Foundation | Epstein foundation connected to grants, payments, and influence activity |
| New York Strategy Group | Epstein affiliated corporate structure |
| JEGE LLC | Epstein controlled entity |
| JEGE Inc. | Epstein controlled entity |
| LSJ, LLC | Entity connected to Little St. James |
| Epstein estate | Holder and administrator of Epstein’s remaining assets |
| Indyke and Kahn | Executors responsible for estate administration |
The complaint should be cross referenced with corporate filings, bank records, operating agreements, property deeds, tax records, estate inventories, and litigation disclosures.
Evidence and Source Limitations
The complaint contains allegations made by Maxwell through counsel. Filing an allegation does not establish that it is true.
The alleged Epstein promises were not attached.
The alleged 2004 letter was not attached.
The NES operating agreement was not attached.
The claimed assurances from Indyke were not supported by attached correspondence.
The complaint did not itemize expenses.
The complaint did not state a total damages figure.
Some victim and case names were redacted.
The filing predates Maxwell’s arrest, trial, conviction, sentence, and appellate proceedings.
The same ten pages carry multiple document numbering systems. Researchers should avoid counting these versions as separate complaints without comparing the underlying pages.
Evidence Appearances
The complaint appears under three parallel identifier systems.
| Complaint page | SDNY discovery number | First EFTA series | Second EFTA series |
|---|---|---|---|
| 1 | SDNY_GM_00324057 | EFTA00196891 | EFTA01306528 |
| 2 | SDNY_GM_00324058 | EFTA00196892 | EFTA01306529 |
| 3 | SDNY_GM_00324059 | EFTA00196893 | EFTA01306530 |
| 4 | SDNY_GM_00324060 | EFTA00196894 | EFTA01306531 |
| 5 | SDNY_GM_00324061 | EFTA00196895 | EFTA01306532 |
| 6 | SDNY_GM_00324062 | EFTA00196896 | EFTA01306533 |
| 7 | SDNY_GM_00324063 | EFTA00196897 | EFTA01306534 |
| 8 | SDNY_GM_00324064 | EFTA00196898 | EFTA01306535 |
| 9 | SDNY_GM_00324065 | EFTA00196899 | EFTA01306536 |
| 10 | SDNY_GM_00324066 | EFTA00196900 | EFTA01306537 |
The presence of duplicate EFTA ranges indicates that the same underlying complaint was reproduced in more than one released record set or discovery sequence.
What the Complaint Establishes
The document establishes that Maxwell filed a civil indemnification action on March 12, 2020.
It establishes that she formally described herself as an employee and property manager for Epstein and several affiliated entities.
It establishes that she claimed employment from approximately 1999 through at least 2006.
It establishes that she claimed responsibility for properties in five jurisdictions.
It establishes that she sought payment for legal fees, security, safe accommodation, and future expenses.
It establishes that she alleged prior financial promises from Epstein and later assurances from Indyke.
It establishes that she claimed employment by NES, C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC, JEGE Inc., and LSJ, LLC.
It establishes that she denied involvement in or knowledge of Epstein’s misconduct as part of her civil pleading.
What the Complaint Does Not Establish
The complaint does not prove that Epstein made the promises Maxwell described.
It does not prove that Indyke agreed to reimburse her.
It does not prove that an enforceable indemnification agreement existed.
It does not prove that NES or another entity was legally required to advance her expenses.
It does not establish the value of Maxwell’s claim.
It does not establish that Maxwell lacked knowledge of Epstein’s conduct.
It does not override her later federal conviction.
It does not establish that the estate paid her.
It does not establish that the court accepted her allegations.
It does not establish the case’s final disposition without the later docket and entered orders.
Investigative Significance
This case provides one of Maxwell’s clearest formal descriptions of her employment relationship with Epstein.
She claimed to have managed properties across the same locations repeatedly identified in survivor testimony. She also connected herself to multiple Epstein entities rather than a single residence or informal romantic relationship.
The complaint presents Epstein’s financial support as part of the relationship. It alleges repeated promises, payment of earlier legal expenses, coverage of settlement costs, support for other employees, and assurances that Maxwell would continue to be protected.
These allegations raise important questions about how Epstein used money, corporate entities, legal fee payments, and indemnification promises to maintain loyalty within his organization.
The filing is also an example of competing claims against Epstein’s estate. While survivors sought compensation for abuse, Maxwell sought payment for the costs of defending herself against claims and investigations arising from the same operation.
Questions for Further Investigation
- Where is the 2004 letter that Maxwell said contained Epstein’s handwritten promise of continuing financial support?
- Did Epstein sign any formal indemnification agreement with Maxwell?
- What indemnification language appeared in the NES operating agreement?
- Did C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC, JEGE Inc., or LSJ, LLC contain indemnification provisions?
- What payments did Epstein make toward Maxwell’s earlier legal fees and settlements?
- Which other employees received indemnification or legal fee advancement from Epstein?
- What documentary evidence supports Maxwell’s allegation that Indyke promised reimbursement?
- What was included in Maxwell’s November 22, 2019 demand letter?
- What was the exact value of the claim submitted to the estate?
- Did the claimed expenses include costs related to the federal criminal investigation that led to her arrest?
- Why did Maxwell characterize herself as a property manager in this lawsuit while presenting her relationship differently in other settings?
- Which activities did Maxwell perform for each named Epstein entity?
- What records accompanied the Virgin Islands Attorney General’s motion to intervene?
- Did the court ever rule on the original May 2020 motion to dismiss?
- Was the later proposed dismissal order signed, dated, and entered?
- Did Maxwell receive any money from the estate while the case was pending?
- Were estate assets reserved for her claim?
- Were any of Maxwell’s legal expenses paid through another Epstein entity, trust, insurer, or third party?
- Did the estate disclose Maxwell’s claim in probate accountings?
- How did the lawsuit affect funds available for survivor compensation?
Sources
- The complete complaint appears in EFTA01306528 through EFTA01306537.
- The duplicate complaint sequence appears in EFTA00196891 through EFTA00196900.
- The Judiciary of the Virgin Islands case collection provides the complaint, initial dismissal motions, motion to stay, motion to intervene, exhibits, stipulation, and early orders.
- The Virgin Islands joint motion to stay explains the one year statutory issue affecting the initial dismissal motion.
- ABC News reporting from March 2020 documents the reported value of the legal claim, survivor attorney responses, and the context surrounding estate assets.
- The Guardian’s March 2020 report documents Giuffre’s response and the conflict between Maxwell’s demand and survivor claims against the estate.
- The federal appellate record upholding Maxwell’s conviction appears in EFTA00156400.