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799 KB
Extraction Summary
5
People
3
Organizations
0
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing (court document - case 1:20-cr-00330-pae)
File Size:
799 KB
Summary
This document is a page from a legal filing (Case 1:20-cr-00330-PAE, US v. Ghislaine Maxwell) arguing for the admissibility of evidence under Rule 404(b). It details the defendant's 'modus operandi' of befriending minors (specifically Minor Victim-3), normalizing sexual topics, and arranging travel to facilitate sexual acts with Epstein. A footnote addresses the defense's anticipated argument regarding lack of knowledge or intent.
People (5)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant |
Referred to throughout the text; Ghislaine Maxwell (implied by case number). Accused of recruiting and grooming minors.
|
| Epstein | Co-conspirator/Perpetrator |
Described as having an attraction to minor girls and using massages to initiate sexual contact.
|
| Minor Victim-3 | Victim |
Subject of the evidence discussed; befriended and encouraged by the defendant to engage in sex acts with Epstein.
|
| Minor Victim-1 | Victim |
Mentioned to establish a pattern/modus operandi similar to Victim-3.
|
| Minor Victim-2 | Victim |
Mentioned to establish a pattern/modus operandi similar to Victim-3.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court |
Implied by case header format.
|
|
| Department of Justice (DOJ) |
Indicated by Bates stamp DOJ-OGR.
|
|
| 2d Cir. |
Second Circuit Court of Appeals, cited in legal precedent.
|
Timeline (1 events)
Unspecified (Past acts)
Relationships (2)
Defendant recruited minors for Epstein, knowing his attraction and intent.
Defendant befriended, encouraged, and groomed the victim for sexual acts.
Key Quotes (3)
"Testimony regarding the defendant’s efforts to recruit and encourage Minor Victim-3 to engage in sex acts with Epstein in the context of massages establishes that the defendant knew of Epstein’s attraction to minor girls and knew that Epstein used massage to initiate sexual contact with minor girls."Source
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Quote #1
"Finally, the details of how the defendant interacted with Minor Victim-3 demonstrates that the defendant had a specific modus operandi when grooming minor girls to engage in sexual activity with Epstein."Source
DOJ-OGR-00003128.jpg
Quote #2
"the defendant asked minor girls details about their lives, normalized sexual topics and activity, and used her presence as an adult woman to convince minor girls that the sexual activity Epstein initiated was normal and acceptable."Source
DOJ-OGR-00003128.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,368 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 194 of 239
404(b)(2); (ii) is relevant to the crime for which the defendant is on trial; (iii) has probative value
that is not substantially outweighed by any unfair prejudicial effect; and (iv) is admitted with a
limiting instruction to the jury, if requested. See Huddleston v. United States, 485 U.S. 681, 691-
92 (1988); United States v. LaFlam, 369 F.3d 153, 156 (2d Cir. 2004).
that is not substantially outweighed by any unfair prejudicial effect; and (iv) is admitted with a
limiting instruction to the jury, if requested. See Huddleston v. United States, 485 U.S. 681, 691-
92 (1988); United States v. LaFlam, 369 F.3d 153, 156 (2d Cir. 2004).
Here, evidence regarding the defendant’s interactions with Minor Victim-3 is admissible
to prove the defendant’s knowledge, intent, and modus operandi, all of which are permissible
purposes under Rule 404(b). Testimony regarding the defendant’s efforts to recruit and encourage
Minor Victim-3 to engage in sex acts with Epstein in the context of massages establishes that the
defendant knew of Epstein’s attraction to minor girls and knew that Epstein used massage to
initiate sexual contact with minor girls. Similarly, testimony regarding the defendant’s interactions
with Minor Victim-3, including how the defendant befriended Minor Victim-3 and then
encouraged her to engage in sex acts with Epstein, establishes that the defendant intended for
minor girls to engage in sex acts with Epstein when she befriended them, invited them to travel,
and arranged for their travel. 60 Finally, the details of how the defendant interacted with Minor
Victim-3 demonstrates that the defendant had a specific modus operandi when grooming minor
girls to engage in sexual activity with Epstein. As with Minor Victim-1 and Minor Victim-2, the
defendant asked minor girls details about their lives, normalized sexual topics and activity, and
used her presence as an adult woman to convince minor girls that the sexual activity Epstein
initiated was normal and acceptable. “The similarity sufficient to admit evidence of past acts to
establish a recurring modus operandi need not be complete; it is enough that the characteristics
relied upon are sufficiently idiosyncratic to permit a fair inference of a pattern’s existence.” United
to prove the defendant’s knowledge, intent, and modus operandi, all of which are permissible
purposes under Rule 404(b). Testimony regarding the defendant’s efforts to recruit and encourage
Minor Victim-3 to engage in sex acts with Epstein in the context of massages establishes that the
defendant knew of Epstein’s attraction to minor girls and knew that Epstein used massage to
initiate sexual contact with minor girls. Similarly, testimony regarding the defendant’s interactions
with Minor Victim-3, including how the defendant befriended Minor Victim-3 and then
encouraged her to engage in sex acts with Epstein, establishes that the defendant intended for
minor girls to engage in sex acts with Epstein when she befriended them, invited them to travel,
and arranged for their travel. 60 Finally, the details of how the defendant interacted with Minor
Victim-3 demonstrates that the defendant had a specific modus operandi when grooming minor
girls to engage in sexual activity with Epstein. As with Minor Victim-1 and Minor Victim-2, the
defendant asked minor girls details about their lives, normalized sexual topics and activity, and
used her presence as an adult woman to convince minor girls that the sexual activity Epstein
initiated was normal and acceptable. “The similarity sufficient to admit evidence of past acts to
establish a recurring modus operandi need not be complete; it is enough that the characteristics
relied upon are sufficiently idiosyncratic to permit a fair inference of a pattern’s existence.” United
60 Such evidence is particularly probative when it seems apparent from defense filings that the
defendant plans to argue that even if she were somehow involved in transporting or traveling with
minors, she had no knowledge or intent that they engage in sexual conduct with Epstein.
defendant plans to argue that even if she were somehow involved in transporting or traveling with
minors, she had no knowledge or intent that they engage in sexual conduct with Epstein.
167
DOJ-OGR-00003128
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