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Extraction Summary

4
People
1
Organizations
1
Locations
3
Events
3
Relationships
4
Quotes

Document Information

Type: Legal document
File Size: 719 KB
Summary

This legal document, part of a court filing, argues for a sentencing enhancement against the defendant, identified as Maxwell. It presents evidence of her leadership role in a criminal conspiracy, citing her authority over an associate named Kellen, which is supported by flight records on Epstein's planes and her delegation of illicit tasks. The document then justifies a specific two-point "Undue Influence" enhancement by referencing U.S. Sentencing Guidelines concerning crimes where an adult participant influences a minor.

People (4)

Name Role Context
Kellen
Mentioned as flying with the defendant on Epstein's planes, joining the conspiracy, and being instructed by Maxwell.
Epstein
Mentioned as the owner of the private planes on which the defendant and Kellen flew.
Maxwell Second in command under Epstein
Identified as being second in command to Epstein, exercising authority over Kellen, and instructing Kellen on schedul...
the defendant Defendant
Referred to throughout the document as the subject of the legal arguments. The context implies the defendant is Maxwe...

Organizations (1)

Name Type Context
U.S.S.G. government agency
Referenced for sentencing guidelines, specifically § 3B1.1 and § 2G1.3(b)(2)(B), regarding leadership enhancement and...

Timeline (3 events)

2003
The defendant and Kellen flew together on Epstein’s private planes approximately thirty-nine times.
Epstein's private planes
2004
The defendant and Kellen flew together on Epstein’s private planes approximately ten times.
Epstein's private planes
Maxwell instructed Kellen on how to run a part of the scheme, and Kellen took over making calls to schedule appointments.

Locations (1)

Location Context
Mentioned to describe the breadth of the defendant's criminal scheme.

Relationships (3)

Maxwell professional Epstein
The document states that "Maxwell was still second in command under Epstein."
Maxwell superior-subordinate Kellen
The document states that Maxwell "exercised authority over Kellen," "instructed Kellen," and that Kellen followed "Maxwell's directions."
the defendant professional Kellen
They flew together on private planes approximately 49 times over two years (2003-2004), indicating a close working relationship within the conspiracy.

Key Quotes (4)

"a participant . . . unduly influenced a minor to engage in prohibited sexual conduct."
Source
— U.S.S.G. § 2G1.3(b)(2)(B) (Quoted from the U.S. Sentencing Guidelines to define the condition for a two-level sentencing enhancement.)
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Quote #1
"a participant’s influence over the minor compromised the voluntariness of the minor’s behavior."
Source
— U.S.S.G. § 2G1.3(b)(2)(B) app. n.3(B) (Quoted from the U.S. Sentencing Guidelines to explain when the undue influence enhancement applies.)
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Quote #2
"a participant is at least 10 years older than the minor,"
Source
— U.S.S.G. Guidelines (A condition cited from the Guidelines that leads to a rebuttable presumption of undue influence.)
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Quote #3
"a rebuttable presumption . . . that such participant unduly influenced the minor to engage in prohibited sexual conduct."
Source
— U.S.S.G. Guidelines (The legal presumption that arises when a participant is at least 10 years older than a minor victim.)
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Quote #4

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