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Extraction Summary

5
People
3
Organizations
5
Locations
2
Events
3
Relationships
2
Quotes

Document Information

Type: Legal correspondence / defense motion letter
File Size: 515 KB
Summary

This document is a legal letter dated December 27, 2021, from defense attorney Christian R. Everdell to Judge Alison J. Nathan during the trial of United States v. Ghislaine Maxwell. The defense requests additional jury instructions to clarify 'apparent errors' in the jury's understanding of Count Four, specifically regarding whether aiding in a return flight (rather than the flight to the location of sexual activity, such as New Mexico) constitutes guilt. The letter references a specific jury note (Court Exhibit #15) and cites the indictment regarding transportation from Florida to New York for sexual acts with Jeffrey Epstein.

People (5)

Name Role Context
Christian R. Everdell Attorney
Sender of the letter, representing the defense (Cohen & Gresser LLP).
Alison J. Nathan Judge
Recipient of the letter, presiding over United States v. Ghislaine Maxwell.
Ghislaine Maxwell Defendant
Subject of the criminal case and Count Four allegations.
Jane Victim/Witness
Pseudonym for an individual allegedly transported for sexual activity.
Jeffrey Epstein Alleged Co-conspirator
Named as the person Jane was intended to engage in sex acts with.

Organizations (3)

Name Type Context
Cohen & Gresser LLP
Firm representing the defense.
United States District Court Southern District of New York
Venue of the trial.
DOJ
Referenced in footer stamp (Department of Justice).

Timeline (2 events)

December 27, 2021
Jury deliberation and submission of a note (Court Exhibit #15).
United States District Court, SDNY
Jury Judge Alison J. Nathan
Unspecified (Historical)
Transportation of Jane from Florida to New York.
Florida to New York

Locations (5)

Location Context
Address of Cohen & Gresser LLP.
Address of the United States Courthouse.
Location mentioned in the jury question regarding flights.
Origin location of transport mentioned in Count Four allegations.
Destination location of transport mentioned in Count Four allegations.

Relationships (3)

Ghislaine Maxwell Co-conspirator/Associate Jeffrey Epstein
Indictment alleges Maxwell arranged transport for sex acts with Epstein.
Christian R. Everdell Attorney-Client Ghislaine Maxwell
Everdell submitting defense motion on behalf of Maxwell.
Jane Victim-Perpetrator Jeffrey Epstein
Allegation that Jane would engage in sex acts with Epstein.

Key Quotes (2)

"Under Count Four (4), [i]f the defendant aided in the transportation of Jane’s return flight, but not the flight to New Mexico where/if the intent was for Jane to engage in sexual activity, can she be found guilty under the second element?"
Source
DOJ-OGR-00020849.jpg
Quote #1
"Count Four alleges that Ms. Maxwell 'arranged for [Jane] to be transported from Florida to New York, New York on multiple occasions with the intention that [Jane] would engage in one or more sex acts with Jeffrey Epstein...'"
Source
DOJ-OGR-00020849.jpg
Quote #2

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