DOJ-OGR-00020852.jpg
636 KB
Extraction Summary
3
People
3
Organizations
3
Locations
3
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / court filing (motion regarding jury instructions)
File Size:
636 KB
Summary
This document is page 4 of a legal filing addressed to Judge Alison J. Nathan dated December 27, 2021, during the trial of Ghislaine Maxwell. The defense argues that the jury appears to be considering convicting Maxwell on Count Four based on events in New Mexico involving a victim named 'Jane,' whereas the indictment specified events in New York. The defense contends that allowing a conviction based on the New Mexico evidence would constitute a 'constructive amendment' or 'substantial variance' from the indictment, which would be a reversible legal error.
People (3)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge |
The Honorable Alison J. Nathan, recipient of the letter.
|
| Jane | Victim/Witness |
Referenced regarding her travel to/from New Mexico and New York, and alleged sexual abuse.
|
| Ghislaine Maxwell | Defendant |
Referred to as 'Ms. Maxwell'; subject of potential conviction on Count Four.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| US District Court |
Implied by Judge Nathan's title and Case number format.
|
|
| The Government |
Prosecution in the case (Department of Justice).
|
|
| DOJ |
Department of Justice (referenced in footer stamp DOJ-OGR-00020852).
|
Timeline (3 events)
2021-12-27
Defense submission to Judge Nathan regarding jury deliberations.
Court
Alison J. Nathan
Defense Counsel
Locations (3)
| Location | Context |
|---|---|
|
Location of Jane's travel and alleged sexual abuse, which the defense argues is outside the scope of Count Four.
|
|
|
Location mentioned in the indictment (Count Four) and where Jane traveled to from Florida.
|
|
|
Location from which Jane traveled to New York.
|
Relationships (1)
Document discusses alleged sexual abuse of Jane and Maxwell's potential conviction.
Key Quotes (4)
"Court Exhibit #15 indicates that the jury is considering a conviction on Count Four based on Jane’s travel to and from New Mexico and alleged sexual abuse that purportedly took place in New Mexico."Source
DOJ-OGR-00020852.jpg
Quote #1
"Should the jury convict on this basis, it would be a constructive amendment and/or a variance from the express language of Count Four."Source
DOJ-OGR-00020852.jpg
Quote #2
"If the Court does not instruct the jury that they cannot convict Ms. Maxwell on Count Four based on the alleged events in New Mexico, it would permit the jury to convict Ms. Maxwell of an offense “other than that charged in the indictment”"Source
DOJ-OGR-00020852.jpg
Quote #3
"A constructive amendment like this is per se reversible error without a showing of prejudice."Source
DOJ-OGR-00020852.jpg
Quote #4
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document