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Extraction Summary

4
People
2
Organizations
2
Locations
3
Events
1
Relationships
4
Quotes

Document Information

Type: Court document (legal filing/memorandum)
File Size: 669 KB
Summary

This page is from a Government legal filing (Document 621, Case 1:20-cr-00330-PAE) arguing against a post-trial motion by the defendant (Ghislaine Maxwell). The Government asserts that the jury did not improperly convict the defendant based solely on sexual abuse of a victim named 'Jane' in New Mexico, but rather followed instructions regarding violations of New York law. The text discusses jury instructions, the lack of New Mexico specific legal charges presented to the jury, and refutes the defense's claim of a constructive amendment or variance.

People (4)

Name Role Context
The Defendant Accused
Subject of the conviction and the motion being argued against (Ghislaine Maxwell based on Case 1:20-cr-00330).
Jane Victim/Witness
Testified about being sexually abused in New Mexico; pseudonym for a victim.
The Jury Fact Finder
Convicted the defendant; subject of the argument regarding their basis for conviction.
The Government Prosecution
Argued the case at trial; filing this document.

Organizations (2)

Name Type Context
The Court
Issued jury instructions and oversaw the trial.
DOJ
Department of Justice (indicated in Bates stamp DOJ-OGR).

Timeline (3 events)

2022-02-25
Filing of Document 621
Court Docket
During Trial
Jane testified about being sexually abused in New Mexico.
Courtroom / concerning New Mexico
During Trial
Government summation.
Courtroom

Locations (2)

Location Context
Location where Jane was allegedly transported to and sexually abused; location of Zorro Ranch.
Jurisdiction of the law the defendant was charged with violating.

Relationships (1)

The Defendant Abuser/Victim (Alleged/Convicted) Jane
Reference to transporting Jane to New Mexico with intent to engage in sexual activity; Jane's testimony of abuse.

Key Quotes (4)

"There is No Substantial Likelihood That The Jury Convicted The Defendant Solely Because Jane was Sexually Abused in New Mexico"
Source
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Quote #1
"The defendant argues that a constructive amendment or variance occurred because the jury “improperly based their conviction solely on the sexual abuse that Jane experienced in New Mexico.”"
Source
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Quote #2
"Similarly, the Court’s charge required the jury to decide whether the defendant intended to violate New York law."
Source
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Quote #3
"Ironically, it is the defendant who proposed instructing the jury on the relevant ages of consent in states other than New York."
Source
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Quote #4

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