DOJ-OGR-00008954.jpg
645 KB
Extraction Summary
3
People
2
Organizations
0
Locations
4
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
645 KB
Summary
This legal document is a motion arguing that Ms. Maxwell's conviction should be vacated and the S2 Indictment dismissed. The defense claims that the government's excessive and prejudicial delay in bringing the prosecution violated her due process rights by causing critical documentary evidence and witnesses to become unavailable. The motion reasserts arguments from previously denied pretrial motions, which the Court had granted leave to renew after the trial.
People (3)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
The central figure of the document, whose conviction the motion seeks to vacate due to pre-indictment delay.
|
| Epstein |
Mentioned as the recipient of sexualized massages in exchange for cash.
|
|
| Carolyn | Potential victim/witness |
Mentioned as one of the individuals who could have been enticed to give massages to Epstein.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Court | government agency |
The judicial body that previously denied and is now being asked to reconsider motions to dismiss the indictment again...
|
| government | government agency |
The prosecuting entity accused of excessive and prejudicial delay in bringing the case against Ms. Maxwell.
|
Timeline (4 events)
Ms. Maxwell filed initial and supplemental pretrial motions claiming violation of due process rights due to prosecution delay.
The Court denied Ms. Maxwell's pretrial motions on the grounds that she failed to show 'actual and substantial prejudice'.
The Court granted Ms. Maxwell leave to renew her motion after the conclusion of her trial.
Ms. Maxwell reasserts her motion to vacate her conviction and dismiss the indictment due to pre-indictment delay.
Relationships (2)
The document discusses a sex trafficking conspiracy involving enticing individuals to give sexualized massages to Epstein, a case in which Ms. Maxwell was convicted.
Ms. Maxwell is making motions to the Court, which has previously ruled on them and is being asked to rule again.
Key Quotes (3)
"recruit, entice, harbor, transport, provide, or obtain"Source
— Legal definition
(Used to define the elements of a trafficking conspiracy.)
DOJ-OGR-00008954.jpg
Quote #1
"grooming"Source
— The document's author
(Used to describe the act of enticing individuals for a commercial sex act.)
DOJ-OGR-00008954.jpg
Quote #2
"actual and substantial prejudice"Source
— The Court
(The legal standard the Court stated Ms. Maxwell failed to meet in her previous motions regarding the delay in prosecution.)
DOJ-OGR-00008954.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,810 characters)
Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 30 of 37
trafficking conspiracy was to “recruit, entice, harbor, transport, provide, or obtain” a minor to engage in a commercial sex act. If the “grooming” had failed to entice Carolyn and others to give sexualized massages to Epstein in exchange for cash, there would be no sex trafficking count.
For these reasons, Counts One, Three, and Five describe a single conspiracy, not multiple conspiracies, and are therefore multiplicitous. Accordingly, the Court should enter judgment on only one of these counts.
III. The Court Should Vacate Ms. Maxwell’s Conviction and Dismiss the S2 Indictment Due to Pre-Indictment Delay.
The Court should vacate Ms. Maxwell’s convictions as to all counts and dismiss the Indictment due to the government’s excessive and prejudicial delay in bringing this prosecution against Ms. Maxwell in violation of her due process rights. Ms. Maxwell previously made this claim in her initial and supplemental pretrial motions. (Dkt. 138, 293). The Court denied the motion each time on the grounds that Ms. Maxwell failed to show “actual and substantial prejudice” caused by the delay. (Dkt. 207 at 16-18; Dkt. 317 at 10). The Court, however, granted Ms. Maxwell leave to renew the motion after the conclusion of trial. (Dkt. 207 at 18; Dkt. 317 at 10). Ms. Maxwell now reasserts the same motion and incorporates the arguments previously made to the Court.
In addition, the record at trial highlighted numerous other examples of how the delay in charging this case substantially prejudiced Ms. Maxwell’s defense. For example, critical documentary records and witnesses that would have allowed Ms. Maxwell to effectively challenge the government’s proof were no longer available, including the following:
25
DOJ-OGR-00008954
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document