DOJ-OGR-00002683.jpg
688 KB
Extraction Summary
5
People
1
Organizations
1
Locations
4
Events
3
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
688 KB
Summary
This legal document, filed on February 4, 2021, argues against allegations in an indictment concerning Ms. Maxwell's interactions with Accuser-3. The defense contends that the alleged events, including Maxwell introducing Accuser-3 to Epstein, occurred in London between 1994 and 1995, by which time Accuser-3 was 16, the legal age of consent in England. Therefore, the document posits that the alleged "sexual abuse" by Epstein was lawful conduct and cannot be considered an "overt act" in furtherance of a conspiracy, especially as no travel was alleged to have been caused by Maxwell.
People (5)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Subject of allegations |
Mentioned throughout the document as the individual whose interactions with accusers are being discussed. Alleged to ...
|
| Accuser-1 | Accuser |
Mentioned in the first sentence as a subject of allegations in the indictment.
|
| Accuser-2 | Accuser |
Mentioned as one of two individuals, besides Accuser-1, with whom Ms. Maxwell had interactions.
|
| Accuser-3 | Accuser |
A central figure in this section of the document. Allegedly groomed and befriended by Ms. Maxwell, introduced to Epst...
|
| Epstein | Alleged perpetrator |
Mentioned as the person to whom Ms. Maxwell introduced Accuser-3. Alleged to have sexually abused Accuser-3 during ma...
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| The government | government agency |
Mentioned in a footnote as having disclosed Accuser-3's birth year.
|
Timeline (4 events)
1994-1995
1994-1995
Ms. Maxwell allegedly introduced Accuser-3 to Epstein and arranged for multiple interactions.
London, England
1994-1995
Epstein allegedly "sexually abused" Accuser-3 during massages that Ms. Maxwell encouraged.
London, England
Locations (1)
| Location | Context |
|---|---|
|
The location where Ms. Maxwell's interactions with Accuser-3 allegedly took place. Also noted as the jurisdiction whe...
|
Relationships (3)
The document states Ms. Maxwell is alleged to have "groomed and befriended" Accuser-3 and introduced her to Epstein.
Ms. Maxwell allegedly introduced Accuser-3 to Epstein, arranged interactions, and encouraged Accuser-3 to massage him, suggesting a close working relationship in these alleged activities.
Key Quotes (5)
"overt acts"Source
— The indictment (as characterized by the document)
(Used to characterize some of Ms. Maxwell's interactions with Accuser-2 and Accuser-3.)
DOJ-OGR-00002683.jpg
Quote #1
"groomed and befriended"Source
— The indictment (as quoted by the document)
(Describing Ms. Maxwell's alleged actions towards Accuser-3 between 1994 and 1995.)
DOJ-OGR-00002683.jpg
Quote #2
"multiple interactions between [Accuser-3] and Epstein"Source
— The indictment (as quoted by the document)
(Describing events allegedly arranged by Ms. Maxwell.)
DOJ-OGR-00002683.jpg
Quote #3
"encouraged [Accuser-3] to massage Epstein, knowing that Epstein would engage in sex acts with [Accuser-3] during those massages."Source
— The indictment (as quoted by the document)
(Detailing Ms. Maxwell's alleged role in the interactions between Epstein and Accuser-3.)
DOJ-OGR-00002683.jpg
Quote #4
"sexually abused"Source
— The indictment (as quoted by the document)
(Describing Epstein's alleged actions towards Accuser-3 during the massages.)
DOJ-OGR-00002683.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (1,979 characters)
Case 1:20-cr-00330-AJN Document 146 Filed 02/04/21 Page 8 of 16
In addition to the allegations regarding Accuser-1, the indictment includes factual allegations regarding Ms. Maxwell’s interactions with two other individuals, Accuser-2 and Accuser-3, some of which are characterized as “overt acts” in furtherance of the two conspiracies. Ms. Maxwell is not alleged, however, to have enticed or otherwise caused either Accuser-2 or Accuser-3 to travel.
Ms. Maxwell’s interactions with Accuser-3 allegedly took place entirely in London, England, where Ms. Maxwell is alleged to have “groomed and befriended” Accuser-3 “between approximately 1994 and 1995.” Id. ¶ 7c. Ms. Maxwell allegedly introduced Accuser-3 to Epstein and arranged for “multiple interactions between [Accuser-3] and Epstein,” during which Ms. Maxwell “encouraged [Accuser-3] to massage Epstein, knowing that Epstein would engage in sex acts with [Accuser-3] during those massages.” Id.
Although the indictment alleges that Epstein “sexually abused” Accuser-3 during the massages (id.), it does not allege that Epstein’s interactions with Accuser-3 were nonconsensual or in violation of any English law. Notably, Ms. Maxwell is not alleged to have met Accuser-3 and introduced her to Epstein until 1994 at the earliest, by which time Accuser-3 had reached age 16³—the legal age of consent in England. Sexual Offences Act 2003 § 9 (Eng.), 2003, c. 42. Thus, it appears that the “sexual abuse” of Accuser-3 that the indictment alleges was lawful conduct.
Nor does the indictment allege any travel by Accuser-3, in interstate or foreign commerce or otherwise, let alone as a result of any action taken by Ms. Maxwell, Epstein, or anyone else. Yet Counts One and Three allege that Ms. Maxwell’s encouragement of Accuser-3 to provide massages to Epstein in the future was somehow an overt act in furtherance of the alleged
³ The government has disclosed that Accuser-3 was born in [REDACTED].
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DOJ-OGR-00002683
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