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Extraction Summary

7
People
2
Organizations
2
Locations
3
Events
3
Relationships
4
Quotes

Document Information

Type: Legal document
File Size: 733 KB
Summary

This legal document is part of a court filing arguing that the government's summation during a trial did not constructively amend the indictment. The prosecution consistently maintained that the defendant and an associate, Epstein, transported underage girls like "Jane" to New York with the intent for them to be sexually abused there. The defense counters that a jury note suggests the conviction was based on intent for activity in New Mexico, not New York, and that the court erred by not providing a supplemental instruction to clarify this point.

People (7)

Name Role Context
D'Amelio
Cited in a legal case, D’Amelio, 683 F.3d at 419.
Jones
Cited in a legal case, United States v. Jones, 847 F. App’x 28, 30 (2d Cir. 2021).
Jane Victim
Mentioned as one of the underage girls transported to New York for sexual activity.
Epstein Accomplice
Mentioned as having intended with the Defendant for victims to be sexually abused in New York.
Bastian
Cited in a legal case, Bastian, 770 F.3d at 223.
Danielson
Quoted in a legal citation from the Bastian case, Danielson, 199 F.3d at 670.
Maxwell Defendant
Referenced in a citation to a court filing, "Maxwell Reply at 2".

Organizations (2)

Name Type Context
Government government agency
Refers to the prosecution in the legal case, arguing against the Defendant.
Court government agency
Refers to the judicial body presiding over the trial, which gave instructions to the jury and responded to a jury note.

Timeline (3 events)

Transporting Jane and other underage girls to New York with the intention that sexual activity would occur.
New York
Defendant Epstein Jane
The Government's summation at trial, where it argued the Defendant intended for victims to be sexually abused in New York.
Court
Government Defendant
The jury convicted the Defendant.
Court
Jury Defendant

Locations (2)

Location Context
The location where the Government argued the Defendant and Epstein intended for sexual activity with underage girls t...
The location where the Defendant contends a jury note revealed the jury convicted her for intending sexual activity t...

Relationships (3)

Defendant co-conspirator Epstein
The document states that the "Defendant and Epstein had intended for the victims to be 'sexually abused in New York'" and that they "enticed Jane to travel to New York to be abused."
Defendant perpetrator-victim Jane
The document describes the Defendant's role in transporting Jane, an underage girl, for the purpose of sexual activity.
Epstein perpetrator-victim Jane
The document states that Epstein, along with the Defendant, enticed Jane to travel to New York to be abused.

Key Quotes (4)

"set of discrete facts consistent with the charge in the indictment"
Source
— D'Amelio, 683 F.3d at 419 (Used to argue that the government's theory of guilt was not new or unidentified.)
DOJ-OGR-00010394.jpg
Quote #1
"fell squarely within the charged scheme"
Source
— United States v. Jones, 847 F. App’x 28, 30 (Used as an example of a case where evidence did not constitute a constructive amendment to an indictment.)
DOJ-OGR-00010394.jpg
Quote #2
"sexually abused in New York"
Source
— Government (Quoted from the Government's summation, describing the intent of the Defendant and Epstein for the victims.)
DOJ-OGR-00010394.jpg
Quote #3
"behavior entirely separate from that identified in the indictment"
Source
— Bastian, 770 F.3d at 223 (A legal standard quoted to argue that the Government's summation did not describe new criminal behavior outside the indictment.)
DOJ-OGR-00010394.jpg
Quote #4

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