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DOJ-OGR-00020851.jpg
623 KB
Extraction Summary
4
People
1
Organizations
3
Locations
3
Events
2
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
623 KB
Summary
This legal document, dated December 27, 2021, is a filing addressed to Judge Alison J. Nathan in the case against Ms. Maxwell. The author argues that for a conviction on Count Four, the jury must only consider evidence related to the violation of New York Penal Law concerning the transportation of 'Jane' from Florida to New York. The document stresses that any conduct that occurred in New Mexico is irrelevant to this specific charge, citing a statement by the government during the trial to support this point and avoid jury confusion.
People (4)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
The document is addressed to The Honorable Alison J. Nathan.
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| Ms. Maxwell | Defendant |
The subject of the legal argument, alleged to have arranged transportation for 'Jane' in violation of New York Penal ...
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| Jane | Alleged Victim |
An individual allegedly transported by Ms. Maxwell from Florida to New York for sex acts with Jeffrey Epstein. Also m...
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| Jeffrey Epstein |
Mentioned as the person with whom 'Jane' was intended to engage in sex acts.
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Organizations (1)
| Name | Type | Context |
|---|---|---|
| Court | government agency |
Referenced throughout the document in the context of the legal proceedings (e.g., 'Court Exhibit #15', 'represented t...
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Timeline (3 events)
Alleged transportation of 'Jane' from Florida to New York, arranged by Ms. Maxwell.
from Florida to New York
Discussion in court about Court Exhibit #15, where the government clarified the scope of the jury charge.
Court
government
Locations (3)
| Location | Context |
|---|---|
|
Mentioned as a location of 'Jane's' alleged travel and sexual activity, which the document argues should be excluded ...
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Mentioned as the origin of 'Jane's' alleged transportation by Ms. Maxwell.
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Mentioned as the destination of 'Jane's' alleged transportation and the jurisdiction whose laws (New York Penal Law) ...
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Relationships (2)
The document alleges Ms. Maxwell arranged for Jane to be transported to engage in sex acts with Jeffrey Epstein.
The indictment alleges that Ms. Maxwell arranged for Jane to be transported for the purpose of engaging in sex acts.
Key Quotes (1)
"The only illegal sexual activity identified in the entirety of the jury charge is a statute in New York. There cannot be any risk of confusion on that score. This particular charge reminds the jury of that and includes that language as well. The jury has not been charged about any laws in New Mexico; so there can’t be any risk of confusion for exactly that reason."Source
— government
(Quoted from a court transcript (Tr. 3140:10-16) during a discussion about Court Exhibit #15, where the government stressed that the charges are based on New York law, not New Mexico law.)
DOJ-OGR-00020851.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (2,075 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page25 of 221
A-225
Case 1:20-cr-00330-AJN Document 566 Filed 12/28/21 Page 3 of 7
A-225
Case 1:20-cr-00330-AJN Document 566 Filed 12/28/21 Page 3 of 7
The Honorable Alison J. Nathan
December 27, 2021
Page 3
December 27, 2021
Page 3
In contrast to a constructive amendment, “[a] variance occurs when the charging terms of the indictment are left unaltered, but the evidence at trial proves facts materially different from those alleged in the indictment.” Id. at 20 (cleaned up).
Court Exhibit #15 indicates that the jury is considering a conviction on the substantive transportation offense charged in Count Four based on Jane’s alleged travel to and from New Mexico and sexual activity that purportedly took place while she was there. That is not what the indictment alleges. Count Four alleges that Ms. Maxwell “arranged for [Jane] to be transported from Florida to New York, New York on multiple occasions with the intention that [Jane] would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55.” S2 Ind. ¶ 21 (emphasis added). As such, a conviction on Count Four must be based on evidence that Ms. Maxwell intended Jane to travel from Florida to New York, and while in New York, engage in one or more sex acts that violated Section 130.55 of the New York Penal Law. The government has represented to the Court on numerous occasions that Ms. Maxwell cannot be convicted on any of the four Mann Act counts, including Count Four, without proof of an intent to violate New York law. That excludes any conduct that may have occurred in New Mexico.
Indeed, in the discussion about Court Exhibit #15, the government stressed this point:
The only illegal sexual activity identified in the entirety of the jury charge is a statute in New York. There cannot be any risk of confusion on that score. This particular charge reminds the jury of that and includes that language as well. The jury has not been charged about any laws in New Mexico; so there can’t be any risk of confusion for exactly that reason.
Tr. 3140:10-16 (emphasis added).
2068538.1
DOJ-OGR-00020851
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