DOJ-OGR-00008671.jpg
759 KB
Extraction Summary
5
People
2
Organizations
5
Locations
5
Events
4
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
759 KB
Summary
This legal document, part of an indictment, outlines several overt acts allegedly committed by Ghislaine Maxwell and Jeffrey Epstein in furtherance of a conspiracy. The acts include the recruitment and sexual exploitation of a minor named Carolyn between 2001 and 2004, involving payments, encouragement to recruit others, and arranging appointments. The document also mentions a separate 1996 incident involving another victim, Annie, and clarifies the legal standard for proving an overt act in a conspiracy case.
People (5)
| Name | Role | Context |
|---|---|---|
| Maxwell | Accused conspirator |
Mentioned throughout as providing an unsolicited massage, inviting a minor to travel, recruiting a minor for sex acts...
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| Annie | Victim |
Received an unsolicited, topless massage from Maxwell in New Mexico in or about 1996.
|
| Carolyn | Victim |
Recruited by Maxwell and Epstein while under 17 to engage in sex acts, received cash payments, was encouraged to recr...
|
| Epstein | Accused conspirator |
Mentioned throughout as inviting a minor to travel, recruiting a minor for sex acts, engaging in sex acts, encouragin...
|
| Ms. Maxwell | Accused conspirator |
Referenced in the legal argument regarding the Government's burden of proof for the overt act.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Federal Express | company |
Used to send a package from Epstein to Carolyn in October 2002.
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| Government | government agency |
Referenced as the prosecuting party that must prove an overt act was committed by a member of the conspiracy.
|
Timeline (5 events)
Locations (5)
| Location | Context |
|---|---|
|
Location where Maxwell allegedly gave Annie an unsolicited massage.
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Carolyn's state of residence, from which she was invited to travel and to which packages were sent.
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Location where Carolyn was recruited to engage in sex acts with Epstein.
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Location from which Epstein's employees sent gifts to Carolyn.
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Location from which Epstein caused a package to be sent to Carolyn in Florida.
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Relationships (4)
The document alleges they acted together to invite, recruit, and encourage Carolyn for sexual exploitation.
Maxwell recruited Carolyn, paid her for sex acts with Epstein, and encouraged her to recruit others.
Epstein engaged in sex acts with Carolyn, had her scheduled for massages, and encouraged her to recruit others.
Full Extracted Text
Complete text extracted from the document (2,290 characters)
Case 1:20-cr-00330-PAE Document 563 Filed 12/18/21 Page 133 of 167
1 New York Penal Law, Section 130.55; (3) In or about 1996, Maxwell provided Annie with an
2 unsolicited massage in New Mexico, during which Annie was topless; (4) Between in or about
3 2001 and in or about 2002, when Carolyn was under the age of 17, Maxwell and Epstein invited
4 Carolyn to travel from Florida to a place outside of Florida with Epstein.
5 With respect to the overt acts for Count Five, the Indictment alleges as follows: (1)
6 Between in or about 2001 and in or about 2004, Epstein and Maxwell recruited Carolyn to
7 engage in sex acts with Epstein at the Palm Beach Residence, after which Epstein and, at times,
8 Maxwell provided Carolyn with hundreds of dollars in cash for each encounter. Carolyn
9 truthfully told both Epstein and Maxwell her age; (2) Between in or about 2001 and in or about
10 2004, Epstein and Maxwell both encouraged and enticed Carolyn to recruit other girls to engage
11 in paid sex acts with Epstein, which she did; (3) Between in or about 2001 and in or about 2004,
12 Epstein’s employees sent Carolyn gifts, including lingerie, from an address in the Southern
13 District of New York to Carolyn’s residence in Florida. For example, on one occasion in or about
14 October of 2002, Epstein caused a package to be sent by Federal Express from an address in
15 Manhattan to Carolyn in Florida; (4) On multiple occasions between in or about 2001 and in or
16 about 2004, Epstein, Maxwell, or one of Epstein’s other employees called Carolyn to schedule an
17 appointment for Carolyn to massage Epstein. For example, in or about April of 2004 and May of
18 2004 another employee of Epstein’s called Carolyn to schedule such appointments.
19 In order for the Government to satisfy this element, it is not necessary for the
20 Government to prove that Ms. Maxwell committed the overt act. It is sufficient for the
21 Government to show that any of the members of the conspiracy knowingly committed some
22 overt act in furtherance of the conspiracy. Further, the overt act need not be one that is alleged in
23 the Indictment. Rather, it can be any overt act that is substantially similar to those acts alleged in
2 unsolicited massage in New Mexico, during which Annie was topless; (4) Between in or about
3 2001 and in or about 2002, when Carolyn was under the age of 17, Maxwell and Epstein invited
4 Carolyn to travel from Florida to a place outside of Florida with Epstein.
5 With respect to the overt acts for Count Five, the Indictment alleges as follows: (1)
6 Between in or about 2001 and in or about 2004, Epstein and Maxwell recruited Carolyn to
7 engage in sex acts with Epstein at the Palm Beach Residence, after which Epstein and, at times,
8 Maxwell provided Carolyn with hundreds of dollars in cash for each encounter. Carolyn
9 truthfully told both Epstein and Maxwell her age; (2) Between in or about 2001 and in or about
10 2004, Epstein and Maxwell both encouraged and enticed Carolyn to recruit other girls to engage
11 in paid sex acts with Epstein, which she did; (3) Between in or about 2001 and in or about 2004,
12 Epstein’s employees sent Carolyn gifts, including lingerie, from an address in the Southern
13 District of New York to Carolyn’s residence in Florida. For example, on one occasion in or about
14 October of 2002, Epstein caused a package to be sent by Federal Express from an address in
15 Manhattan to Carolyn in Florida; (4) On multiple occasions between in or about 2001 and in or
16 about 2004, Epstein, Maxwell, or one of Epstein’s other employees called Carolyn to schedule an
17 appointment for Carolyn to massage Epstein. For example, in or about April of 2004 and May of
18 2004 another employee of Epstein’s called Carolyn to schedule such appointments.
19 In order for the Government to satisfy this element, it is not necessary for the
20 Government to prove that Ms. Maxwell committed the overt act. It is sufficient for the
21 Government to show that any of the members of the conspiracy knowingly committed some
22 overt act in furtherance of the conspiracy. Further, the overt act need not be one that is alleged in
23 the Indictment. Rather, it can be any overt act that is substantially similar to those acts alleged in
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DOJ-OGR-00008671
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