DOJ-OGR-00010379.jpg
724 KB
Extraction Summary
8
People
2
Organizations
6
Locations
4
Events
5
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
724 KB
Summary
This legal document details how the Defendant and Epstein used financial gifts and payments as a method of grooming victims like Jane and Annie, paying for things like lessons, school, and promising trips. The document also discusses the geographic scope of the criminal conspiracy, noting that while specific counts focused on New York and Florida, witnesses testified to sexual conduct occurring in New Mexico and London as well. The text highlights the testimony of victims, including Carolyn and Virginia Roberts, who were paid for sexualized massages.
People (8)
| Name | Role | Context |
|---|---|---|
| Epstein |
Mentioned as acquiring victims' trust, giving financial gifts, paying for lessons and clothes, and receiving sexualiz...
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| Jane | witness |
Testified that she was given money by Epstein on almost every visit and that he paid for her voice lessons, clothes, ...
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| Annie | victim |
Mentioned as someone who was promised a trip to Thailand by Epstein as part of the grooming process.
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| Carolyn | victim |
Mentioned as being paid to give Epstein sexualized massages at his residence in Florida.
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| Virginia Roberts | victim |
Mentioned as being paid, along with Carolyn, to give Epstein sexualized massages at his residence in Florida.
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| Unnamed Defendant | Defendant |
Mentioned throughout as working with Epstein to acquire victims' trust and extend the period of sexual abuse. The fin...
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| Haji |
Mentioned in the legal case citation 'Haji v. Miller'.
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| Miller |
Mentioned in the legal case citation 'Haji v. Miller'.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Emphasized that financial gifts were part of the Defendant's grooming playbook.
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| The Court | judicial body |
Mentioned as having admitted testimony concerning sexual conduct in various locations.
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Timeline (4 events)
The Defendant and Epstein used financial gifts and payments to acquire victims' trust and extend the period of sexual abuse.
Count Three of the case focused on a conspiracy to transport minors to New York for criminal sexual activity.
New York
Witnesses testified about sexual conduct by the Defendant or Epstein.
Florida, New Mexico, or London
Beginning in 2001
The financial quid pro quo between the Defendant, Epstein, and victims may have become more explicit.
Locations (6)
| Location | Context |
|---|---|
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A trip to Thailand was promised to Annie.
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The objective of the conspiracy in Count Three was to transport minors to New York for criminal sexual activity.
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Location of Epstein's residence where Carolyn and Virginia Roberts were paid for sexualized massages. Also mentioned ...
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Mentioned as a location where sexual conduct by the Defendant or Epstein occurred.
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Mentioned as a location where sexual conduct by the Defendant or Epstein occurred.
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Eastern District of New York, mentioned in a legal citation.
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Relationships (5)
The document states they worked together to acquire victims' trust and extend the period of sexual abuse, and that financial gifts were part of the 'Defendant's playbook'.
Epstein gave Jane money, paid for her lessons, clothes, and school as part of a grooming and coercion scheme.
Epstein promised to send Annie on a trip to Thailand as part of the grooming process.
Virginia Roberts was paid to give Epstein sexualized massages in Florida.
Key Quotes (5)
"[a]lmost every visit"Source
— Jane
(Describing how often she was given money.)
DOJ-OGR-00010379.jpg
Quote #1
"Then came the next step in the playbook: Making these girls feel special, giving them gifts, making friends, giving them money, promising to help with their futures, promises like sending Annie on a trip to Thailand or helping to pay for Jane’s voice lessons and tuition."Source
— Government (prosecution)
(Describing the Defendant's playbook of grooming.)
DOJ-OGR-00010379.jpg
Quote #2
"[Jane] told you that Epstein gave her money and gifts and paid for school. That money wasn’t free . . . . That is inducement, that is enticement, that is coercion."Source
— Government (prosecution)
(Explaining the nature of the financial gifts as a form of coercion.)
DOJ-OGR-00010379.jpg
Quote #3
"a wholly new agreement"Source
— Haji v. Miller case
(Used to argue that the shift in approach in 2001 was not dramatic enough to constitute a new conspiracy.)
DOJ-OGR-00010379.jpg
Quote #4
"conspiratorial objective"Source
— Haji v. Miller case
(Used in the context of describing the shift in approach in 2001.)
DOJ-OGR-00010379.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,122 characters)
Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 13 of 45
Further, in both counts, the witnesses testified that they received financial gifts and payments as a means by which the Defendant and Epstein acquired their victims’ trust and extended the period of sexual abuse. E.g., id. at 302 (Jane testified that she was given money “[a]lmost every visit” and that Epstein paid for things like voice lessons and clothes). The Government emphasized such financial gifts as one step in the Defendant’s playbook of grooming. E.g., id. at 2851 (“Then came the next step in the playbook: Making these girls feel special, giving them gifts, making friends, giving them money, promising to help with their futures, promises like sending Annie on a trip to Thailand or helping to pay for Jane’s voice lessons and tuition.”), 2890 (“[Jane] told you that Epstein gave her money and gifts and paid for school. That money wasn’t free . . . . That is inducement, that is enticement, that is coercion.”). The financial quid pro quo may have become more explicit beginning in 2001, but that shift in approach is not nearly so dramatic as to suggest that the Defendant and Epstein at that time entered “a wholly new agreement” with a new “conspiratorial objective.” Haji v. Miller, 584 F. Supp. 2d 498, 519 (E.D.N.Y. 2008). The similarity-of-operations factor therefore favors the Defendant.
Overlap of geographic scope. There is some, albeit incomplete, geographic overlap between the two counts. Count Three focused on travel to New York because the ultimate objective of the conspiracy was to transport minors to New York to engage in criminal sexual activity in violation of New York law. Count Five, by contrast, focused on Epstein’s residence in Florida, where Carolyn and Virginia Roberts were paid to give Epstein sexualized massages. Nevertheless, some geographic overlap between the two counts remained. All four witnesses testified about sexual conduct by the Defendant or Epstein in locations other than New York, whether Florida, New Mexico, or London. The Court admitted such testimony concerning
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DOJ-OGR-00010379
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