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742 KB
Extraction Summary
6
People
2
Organizations
1
Locations
2
Events
3
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
742 KB
Summary
This legal document is a portion of a government filing arguing against a defendant's motion for a bill of particulars. The government contends that the S2 Indictment provides sufficient detail for the defendant to prepare a defense for Counts Five and Six, which relate to her alleged participation in a conspiracy with Epstein to commit sex trafficking of minors. Specifically, the charges involve the trafficking of 'Minor Victim-4' between approximately 2001 and 2004.
People (6)
| Name | Role | Context |
|---|---|---|
| Epstein |
Mentioned as a co-conspirator with the defendant in the sex trafficking of minors, specifically Minor Victim-4.
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| Minor Victim-4 | Victim |
Identified as a particular minor who was allegedly sex trafficked by the defendant and Epstein from approximately 200...
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| Torres |
Party in the case citation United States v. Torres, used to define the purpose of a bill of particulars.
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| Marcus |
Party in the case citation United States v. Marcus, which abrogated the Torres case on other grounds.
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| Walsh |
Party in the case citation United States v. Walsh, used to define when a bill of particulars is required.
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| Mahabub |
Party in the case citation United States v. Mahabub.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
The prosecuting party that has provided the defendant with the S2 Indictment and discovery.
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| Court | judicial body |
Mentioned as having denied the defendant's prior motion for a bill of particulars.
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Timeline (2 events)
2001-2004
Alleged conspiracy to commit sex trafficking of minors and the sex trafficking of Minor Victim-4.
2021-05-25
The Government filed a document arguing that the defendant's motion for a bill of particulars regarding Counts Five and Six of the S2 Indictment should be denied.
Government
defendant
Locations (1)
| Location | Context |
|---|---|
|
Southern District of New York, mentioned in the citation for United States v. Mahabub.
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Relationships (3)
The document states that Counts Five and Six concern the defendant's participation in a conspiracy with Epstein to commit sex trafficking of minors.
The document alleges the defendant participated in and aided and abetted the sex trafficking of Minor Victim-4 with Epstein.
The document alleges the sex trafficking of Minor Victim-4 with Epstein.
Key Quotes (2)
"to provide defendant with information about the details of the charge against him if this is necessary to the preparation of his defense, and to avoid prejudicial surprise at trial."Source
— United States v. Torres
(Quoted to explain the proper purpose of a bill of particulars under Federal Rule of Criminal Procedure 7(f).)
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Quote #1
"[a] bill of particulars is required ‘only where the charges of the indictment are so general that they do not advise the defendant of the specific acts of which he is accused.’"Source
— United States v. Walsh (quoting Torres)
(Quoted to establish the legal standard for when a bill of particulars is warranted.)
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Quote #2
Full Extracted Text
Complete text extracted from the document (2,238 characters)
Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 21 of 26
VI. A Bill of Particulars Is Not Warranted
The defendant again seeks a bill of particulars, this time related to Counts Five and Six of the S2 Indictment. Because the Government has provided the defendant with more than sufficient information—through both the S2 Indictment and discovery—to understand the charges against her, to prepare a defense, and to protect against double jeopardy, this motion should be denied. The instant motion seeks essentially the same type of details that the defendant sought with regards to Counts One through Four in her prior motions. For the same reasons that the Court denied that prior motion, this motion should also be denied. (See Apr. Op. at 19).
The proper purpose of a bill of particulars under Federal Rule of Criminal Procedure 7(f) is “to provide defendant with information about the details of the charge against him if this is necessary to the preparation of his defense, and to avoid prejudicial surprise at trial.” United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir. 2010) (emphasis added) (internal quotation marks omitted). Accordingly, “[a] bill of particulars is required ‘only where the charges of the indictment are so general that they do not advise the defendant of the specific acts of which he is accused.’” United States v. Walsh, 194 F.3d 37, 47 (2d Cir. 1999) (quoting Torres, 901 F.2d at 234); see United States v. Mahabub, No. 13 Cr. 908 (AJN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug. 26, 2014).
As was the case with the charges contained in the prior indictment, the charges contained in Counts Five and Six of the S2 Indictment are clear from the face of the charging instrument, which provides significant detail. As is apparent from the 23-page speaking S2 Indictment, Counts Five and Six concern the defendant’s participation in a conspiracy to commit sex trafficking of minors with Epstein and her participation in, and aiding and abetting of, the sex trafficking of a particular minor identified as Minor Victim-4 with Epstein from approximately 2001 through 2004.
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