DOJ-OGR-00010428.jpg
699 KB
Extraction Summary
6
People
3
Organizations
1
Locations
3
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
699 KB
Summary
This legal document, filed on June 15, 2022, argues that the defendant's offense conduct concluded by summer 2004. It disputes the validity of unauthenticated message slips (GX 4) presented by the government, contrasting them with other message books (GX 1-3) that were authenticated by Juan Alessi and Nicole Hesse and admitted into evidence. A footnote references a 2007 FBI interview with a victim, Carolyn, who stated her interactions with Epstein began when she was 14 and ended when she was 17.
People (6)
| Name | Role | Context |
|---|---|---|
| Carolyn |
Mentioned as the person who performed 'sexualized messages' for Epstein and was interviewed by the FBI in 2007.
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| Epstein |
Mentioned as the recipient of 'sexualized messages' from Carolyn and whom Carolyn visited at his residence.
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| Juan Alessi |
Recognized signatures and/or handwriting in message books (GX 1-3), helping to establish them as business records.
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| Nicole Hesse |
Recognized signatures and/or handwriting in message books (GX 1-3), helping to establish them as business records.
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| Cordoba-Murgas | Defendant |
Mentioned in the case citation 'United States v. Cordoba-Murgas'.
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| Gigante | Defendant |
Mentioned in the case citation 'United States v. Gigante'.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| government | government agency |
Cited message pad slips as evidence (GX 4-B, GX 4-F) and is presumed not to have had a witness to authenticate other ...
|
| The Court | government agency |
Admitted certain message slips (GX 1-3) into evidence but not others (GX 4-A-K). The document argues the Court should...
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| FBI | government agency |
Conducted an interview with Carolyn in 2007, as mentioned in a footnote.
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Timeline (3 events)
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in a footnote as the location Carolyn visited 'over 100 times'.
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Relationships (2)
The document states that 'Carolyn stopped performing sexualized messages for Epstein'. A footnote details that she began visiting his residence when she was 14 years old and last visited when she was 17.
They are mentioned together as individuals who could recognize signatures and handwriting in message books, suggesting they worked in a capacity that made them familiar with these business records.
Key Quotes (3)
"excessive, inappropriate, and unintended under Sentencing Guidelines"Source
— United States v. Cordoba-Murgas
(Describing sentences that can result from enhancements based on relevant conduct imposed without regard to the weight of evidence.)
DOJ-OGR-00010428.jpg
Quote #1
"the preponderance standard is no more than a threshold basis for adjustments and departures, and the weight of the evidence, at some point along a continuum of sentence severity, should be considered"Source
— United States v. Gigante
(A holding regarding the standard for sentencing purposes.)
DOJ-OGR-00010428.jpg
Quote #2
"over 100 times for approximately three years beginning when she was 14 years old."Source
— Carolyn
(A statement made during her 2007 interview with the FBI regarding her visits to Epstein's residence.)
DOJ-OGR-00010428.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,178 characters)
Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 11 of 29
evidence indicates that Carolyn stopped performing sexualized messages for Epstein at the latest in the summer of 2004, not in 2005.5
The two message pad slips cited by the government (GX 4-B, GX 4-F) do not support a finding that the offense conduct lasted beyond November 1, 2004. Although these two messages were labeled as government exhibits along with the rest of the message slips in the same book (GX 4-A-K), these messages were never admitted in evidence. The Court admitted the message slips from three other message books (GX 1-3) because Juan Alessi and Nicole Hesse recognized their signatures and/or handwriting in those books and could establish a business records foundation for their admission. (Tr. 877-889, 1772-1790). The government presumably did not have anyone who could do the same for GX 4 or it would certainly have admitted the message slips from that book as well. The Court should not rely on two isolated, unauthenticated documents in determining when the offense conduct ended, especially when they would almost single-handedly increase the recommended sentencing range by over 10 years. Cf. United States v. Cordoba-Murgas, 233 F.3d 704, 708 (2d Cir. 2000) (acknowledging that enhancements based on relevant conduct may result in sentences that are “excessive, inappropriate, and unintended under Sentencing Guidelines” when imposed “without regard to the weight of the evidence proving the relevant conduct”); United States v. Gigante, 94 F.3d 53, 56 (2d Cir. 1996) (holding that, for sentencing purposes, “the preponderance standard is no more than a threshold basis for adjustments and departures, and the weight of the evidence, at some point along a continuum of sentence severity, should be considered”) (emphasis in original).
5 In her 2007 interview with the FBI, which the government cites in its own objections to the PSR, Carolyn stated that she went to Epstein’s residence “over 100 times for approximately three years beginning when she was 14 years old.” See PSR at 54. According to that timeline, Carolyn last visited Epstein when she was 17.
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DOJ-OGR-00010428
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