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513 KB
Extraction Summary
3
People
3
Organizations
6
Locations
1
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
513 KB
Summary
This legal document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan, dated December 19, 2021, concerning the case of United States v. Ghislaine Maxwell. The Government identifies a significant ambiguity in Jury Instruction No. 19, where the pronoun "she" could be interpreted as referring to either the defendant or the victim. To resolve this, the Government proposes that the court replace "she" with "the individual" to ensure clarity for the jury.
People (3)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge, United States District Court |
Recipient of the letter, addressed as "The Honorable Alison J. Nathan" and "Dear Judge Nathan".
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| Ghislaine Maxwell | Defendant |
Named as the defendant in the case referenced in the letter: "United States v. Ghislaine Maxwell".
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| Silvio J. Mollo |
The U.S. Attorney's office is located in "The Silvio J. Mollo Building".
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice | Government agency |
The sender of the letter.
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| United States Attorney, Southern District of New York | Government agency |
The specific office sending the letter on behalf of the U.S. Government.
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| United States District Court, Southern District of New York | Government agency |
The court where Judge Alison J. Nathan presides and where the case is being heard.
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Timeline (1 events)
2021-12-19
The U.S. Government submitted a letter to the court regarding an ambiguity in the jury charge for the trial of Ghislaine Maxwell.
United States District Court, Southern District of New York
U.S. Government
Judge Alison J. Nathan
Locations (6)
| Location | Context |
|---|---|
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The jurisdiction of the U.S. Attorney and the U.S. District Court mentioned.
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The location of the United States Attorney's office.
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The address of the United States Attorney's office.
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The location of the United States District Court.
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The address of the United States Courthouse.
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The city where the U.S. Attorney's office and the Courthouse are located.
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Relationships (2)
The document is a filing in the criminal case "United States v. Ghislaine Maxwell", where the U.S. Government is the prosecution and Ghislaine Maxwell is the defendant.
The U.S. Government, as a party in a legal case, is formally addressing the presiding judge, Alison J. Nathan, regarding court proceedings.
Key Quotes (2)
"the Defendant transported the individual with the intent that she would engage in sexual activity for which any person can be charged with a criminal offense under New York law, as alleged in the Indictment."Source
— Instruction No. 19
(The text of the second element of a jury instruction which the Government claims is ambiguous.)
DOJ-OGR-00008436.jpg
Quote #1
"The second element of Count Four which the Government must prove beyond a reasonable doubt is"Source
— Instr. No. 21
(A partial quote from another jury instruction, cited by the Government in its proposal to amend Instruction No. 19.)
DOJ-OGR-00008436.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,308 characters)
Case 1:20-cr-00330-PAE Document 556 Filed 12/19/21 Page 1 of 2
U.S. Department of Justice
United States Attorney
Southern District of New York
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
One Saint Andrew’s Plaza
New York, New York 10007
December 19, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter regarding the jury charge. The Government notes one point, which is not the result of an error but which is a significant ambiguity that the Government identified while reviewing the Court’s revisions.
In Instruction No. 19, the second element reads that “the Defendant transported the individual with the intent that she would engage in sexual activity for which any person can be charged with a criminal offense under New York law, as alleged in the Indictment.” It is ambiguous whether the “she” in this sentence refers to the Defendant or the individual. The Government proposes that the Court replace “she” with “the individual.” See Instr. No. 21 (“The second element of Count Four which the Government must prove beyond a reasonable doubt is
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DOJ-OGR-00008436
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