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647 KB
Extraction Summary
5
People
2
Organizations
0
Locations
3
Events
1
Relationships
8
Quotes
Document Information
Type:
Legal document
File Size:
647 KB
Summary
This legal document, dated February 28, 2023, discusses a 'pyramid scheme of abuse' involving a defendant and Jeffrey Epstein, spanning over a decade. It details how massage was used as a primary method to normalize contact, instigate sexual abuse, and lure young girls, with the defendant also providing cash. The text references trial testimony and legal precedents to argue the continuity and nature of the abuse scheme.
People (5)
| Name | Role | Context |
|---|---|---|
| defendant | Defendant |
Central figure in the 'pyramid scheme of abuse'; played an essential role; normalized bodily contact; instigated sexu...
|
| Jeffrey Epstein |
Involved with the defendant in the 'pyramid scheme of abuse'; normalized bodily contact; instigated sexual abuse; gir...
|
|
| Pena |
Party in the legal case *United States v. Pena* cited as precedent.
|
|
| Berger |
Party in the legal case *United States v. Berger* cited as precedent.
|
|
| Maldonado-Rivera |
Party in the legal case *United States v. Maldonado-Rivera* cited as precedent.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States | Government agency |
Party in legal cases cited as precedent (*United States v. Pena*, *United States v. Berger*, *United States v. Maldon...
|
| Government | Government agency |
Party in the legal proceedings; distinguished between phases of abuse; emphasized defendant's role; suggested differe...
|
Timeline (3 events)
before and after 2001
Defendant and Epstein normalized bodily contact and commonly instigated instances of sexual abuse, primarily through massage.
Defendant
Epstein
victims
Relationships (1)
the Defendant and Epstein normalized bodily contact and also the means by which the Defendant and Epstein commonly instigated instances of sexual abuse.
Key Quotes (8)
"a decade,” having both the “earlier phase” and the later “pyramid scheme.”"Source
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Quote #1
"the beginning of the pyramid scheme of abuse"Source
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Quote #2
"two or more phases or spheres of operation"Source
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Quote #3
"[f]or a decade, the defendant played an essential role in this scheme,"Source
— Government
(Government's emphasis on the defendant's role.)
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Quote #4
"You will learn that in the 1990s, they used the cover of mentoring young girls . . . to introduce massage . . . and that you will learn that they used these so called massages as a way to sexually abuse the victims."Source
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Quote #5
"Under this pyramid scheme of abuse, the defendant could just call girls to schedule massage appointments and hand them cash afterwards . . . ."Source
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Quote #6
"You will learn that the cover of massage was the primary way the defendant and Epstein lured girls into sexual abuse."Source
DOJ-OGR-00020995.jpg
Quote #7
"Again and again throughout this trial, you heard about how these girls were asked to perform sexualized massages on Jeffrey Epstein."Source
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Quote #8
Full Extracted Text
Complete text extracted from the document (2,197 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page169 of 221
A-369
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 12 of 45
A-369
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 12 of 45
a decade,” having both the “earlier phase” and the later “pyramid scheme.” Trial Tr. at 40; see
also, e.g., id. at 2886 (describing 2001 as “the beginning of the pyramid scheme of abuse”). But
a single conspiracy can enter “two or more phases or spheres of operation” without creating a
discontinuity in the underlying unlawful agreement, particularly if the same people are serving
the same roles in each phase. United States v. Pena, 846 F. App’x 49, 51 (2d Cir. 2021)
(summary order) (quoting United States v. Berger, 224 F.3d 107, 114–15 (2d Cir. 2000)); see
also United States v. Maldonado-Rivera, 922 F.2d 934, 963 (2d Cir. 1990). Notably, the
Government, after distinguishing between earlier and later phases in the pattern of abuse,
immediately emphasized that “[f]or a decade, the defendant played an essential role in this
scheme,” blurring any difference between the two phases. Trial Tr. at 41.
Moreover, though these phases did involve some differing means to acquire minor
victims, the differences presented at trial were not as great as the Government suggests in its
brief. As to both counts, both before and after 2001, the Government emphasized that massage
was a primary means by which the Defendant and Epstein normalized bodily contact and also the
means by which the Defendant and Epstein commonly instigated instances of sexual abuse.
Compare id. at 40 (“You will learn that in the 1990s, they used the cover of mentoring young
girls . . . to introduce massage . . . and that you will learn that they used these so called massages
as a way to sexually abuse the victims.”), with id. at 41 (“Under this pyramid scheme of abuse,
the defendant could just call girls to schedule massage appointments and hand them cash
afterwards . . . .”); e.g., id. at 35 (“You will learn that the cover of massage was the primary way
the defendant and Epstein lured girls into sexual abuse.”), 2852 (“Again and again throughout
this trial, you heard about how these girls were asked to perform sexualized massages on Jeffrey
Epstein.”).
also, e.g., id. at 2886 (describing 2001 as “the beginning of the pyramid scheme of abuse”). But
a single conspiracy can enter “two or more phases or spheres of operation” without creating a
discontinuity in the underlying unlawful agreement, particularly if the same people are serving
the same roles in each phase. United States v. Pena, 846 F. App’x 49, 51 (2d Cir. 2021)
(summary order) (quoting United States v. Berger, 224 F.3d 107, 114–15 (2d Cir. 2000)); see
also United States v. Maldonado-Rivera, 922 F.2d 934, 963 (2d Cir. 1990). Notably, the
Government, after distinguishing between earlier and later phases in the pattern of abuse,
immediately emphasized that “[f]or a decade, the defendant played an essential role in this
scheme,” blurring any difference between the two phases. Trial Tr. at 41.
Moreover, though these phases did involve some differing means to acquire minor
victims, the differences presented at trial were not as great as the Government suggests in its
brief. As to both counts, both before and after 2001, the Government emphasized that massage
was a primary means by which the Defendant and Epstein normalized bodily contact and also the
means by which the Defendant and Epstein commonly instigated instances of sexual abuse.
Compare id. at 40 (“You will learn that in the 1990s, they used the cover of mentoring young
girls . . . to introduce massage . . . and that you will learn that they used these so called massages
as a way to sexually abuse the victims.”), with id. at 41 (“Under this pyramid scheme of abuse,
the defendant could just call girls to schedule massage appointments and hand them cash
afterwards . . . .”); e.g., id. at 35 (“You will learn that the cover of massage was the primary way
the defendant and Epstein lured girls into sexual abuse.”), 2852 (“Again and again throughout
this trial, you heard about how these girls were asked to perform sexualized massages on Jeffrey
Epstein.”).
12
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