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713 KB
Extraction Summary
3
People
2
Organizations
3
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / court filing (page 4)
File Size:
713 KB
Summary
This document is page 4 of a legal submission to Judge Alison J. Nathan (dated Dec 27, 2021) in the case of United States v. Ghislaine Maxwell. The text argues that the jury must be instructed not to convict Maxwell on Count Four based on the victim 'Jane's' travel to New Mexico, as the indictment specifically charged travel to New York. The defense contends that a conviction based on the New Mexico events would constitute a 'constructive amendment' or 'variance' from the indictment, which is reversible error.
People (3)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge |
The Honorable, recipient of the letter
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| Jane | Victim/Witness |
Subject of alleged travel and sexual abuse; central to Count Four argument
|
| Ghislaine Maxwell | Defendant |
Referred to as 'Ms. Maxwell'; subject of potential conviction on Count Four
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States District Court |
Implied by 'Case 1:20-cr-00330-PAE' and 'The Honorable Alison J. Nathan'
|
|
| Department of Justice |
DOJ-OGR footer code
|
Locations (3)
| Location | Context |
|---|---|
|
Location of alleged travel and sexual abuse discussed as potential basis for conviction
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Location specified in the indictment (Count Four) regarding travel and violation of law
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Origin point of Jane's alleged travel to New York
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Relationships (1)
Discussion of convicting Ms. Maxwell based on acts involving Jane.
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
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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
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Quote #2
"A constructive amendment like this is per se reversible error without a showing of prejudice."Source
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Quote #3
"Ms. Maxwell has no burden to prove prejudice at this point since the variance can still be prevented"Source
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Quote #4
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