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697 KB
Extraction Summary
4
People
3
Organizations
1
Locations
4
Events
1
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
697 KB
Summary
This legal document, filed on February 11, 2022, is a motion from the government following the conviction of Ms. Maxwell on three conspiracy counts. The government argues that since the evidence at trial proved a single, overarching conspiracy with Jeffrey Epstein, punishing her for all three counts would constitute double jeopardy. Accordingly, the government requests that the Court impose judgment on only one of the three conspiracy counts.
People (4)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Mentioned throughout the document as the defendant who was convicted on three conspiracy counts and previously moved ...
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| Jeffrey Epstein | Co-conspirator |
Mentioned as a co-conspirator with Ms. Maxwell in a scheme to abuse minor victims.
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| Josephburg |
Mentioned in the case citation United States v. Josephburg.
|
|
| Chacko |
Mentioned in the case citation United States v. Chacko.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court | government agency |
The judicial body that previously denied Ms. Maxwell's motion to dismiss and is now being moved to impose judgment.
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| Second Circuit | government agency |
A U.S. Court of Appeals whose legal holdings are cited in the document.
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| DOJ | government agency |
Appears in the footer document identifier 'DOJ-OGR-00008948', indicating the Department of Justice.
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Timeline (4 events)
Ms. Maxwell moved to dismiss the multiplicitous conspiracy counts in her pretrial motions.
The Court denied Ms. Maxwell’s motion without prejudice, deferring the resolution of the multiplicity claim until after the conclusion of the trial.
Ms. Maxwell was convicted on all three conspiracy counts.
Locations (1)
| Location | Context |
|---|---|
|
Locations to which minor victims were enticed to travel.
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Relationships (1)
The document states they were involved in a 'scheme to abuse minor victims' and that Ms. Maxwell participated in a 'single criminal conspiracy with Epstein'.
Key Quotes (1)
"An indictment is multiplicitous when it charges a single offense as an offense multiple times, in separate counts, when, in law and fact, only one crime has been committed."Source
— United States v. Chacko
(A legal definition of a multiplicitous indictment, cited as applicable law.)
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Quote #1
Full Extracted Text
Complete text extracted from the document (2,035 characters)
Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 24 of 37
a part and furtherance of their scheme to abuse minor victims, [Ms. Maxwell] and Jeffrey Epstein enticed and caused minor victims to travel to Epstein’s residences in different states, which [Maxwell] knew and intended would result in their grooming for and subjection to sexual abuse.”).
Ms. Maxwell moved to dismiss the multiplicitous conspiracy counts in her pretrial motions. (Dkt. 122, 210, 293). The Court, citing the Second Circuit’s holding in United States v. Josephburg, 459 F.3d 350, 355 (2d Cir. 2006), found that the motion was premature because Ms. Maxwell had not been convicted on the conspiracy counts and, hence, was not yet in jeopardy of receiving multiple punishments for the same offense. (Dkt. 207 at 27-28; Dkt 317 at 9-10). The Court denied Ms. Maxwell’s motion without prejudice, deferring the resolution of the multiplicity claim until after the conclusion of the trial. Id.
The trial is now over, and Ms. Maxwell was convicted on all three conspiracy counts. The government’s theory of prosecution and the proof elicited at trial were entirely aligned with the allegations in the Indictment – that Ms. Maxwell participated in a single criminal conspiracy with Epstein, which may have evolved slightly over time, but always maintained the same overarching objective, the same core participants, and the same method of operation throughout the entire time period in the Indictment. Ms. Maxwell now faces the prospect of being punished multiple times for the same offense in violation of her rights under the Double Jeopardy Clause. Accordingly, we move the Court to impose judgement on only one of the three conspiracy counts.
A. Applicable Law
“An indictment is multiplicitous when it charges a single offense as an offense multiple times, in separate counts, when, in law and fact, only one crime has been committed.” United States v. Chacko, 169 F.3d 140, 145 (2d Cir. 1999). Multiplicitous indictments violate the
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DOJ-OGR-00008948
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