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762 KB
Extraction Summary
6
People
2
Organizations
4
Locations
1
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing / court motion (page 28 of 37)
File Size:
762 KB
Summary
This document is page 28 of a legal filing (Document 600) in the case US v. Maxwell, filed on February 11, 2022. It outlines the government's theory that Epstein and Maxwell operated a single criminal conspiracy using a specific 'playbook' to groom vulnerable minors across multiple locations (NY, Palm Beach, NM, USVI). The text cites trial transcripts regarding four specific accusers (Jane, Annie, Carolyn, Kate) and describes the targeting of children from single-mother households.
People (6)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Described as running a 'playbook' to exploit young girls; subject of the trial.
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| Jeffrey Epstein | Co-conspirator |
Described as engaging in a single criminal scheme with Maxwell.
|
| Jane | Accuser/Victim |
Mentioned in trial transcript as a victim of the 'playbook'.
|
| Annie | Accuser/Victim |
Mentioned in trial transcript as a victim of the 'playbook'.
|
| Carolyn | Accuser/Victim |
Mentioned in trial transcript as a victim of the 'playbook'.
|
| Kate | Accuser/Victim |
Mentioned in trial transcript as a victim of the 'playbook'.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
Presented the charging theory and evidence at trial.
|
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| DOJ |
Referenced in the footer stamp (DOJ-OGR).
|
Locations (4)
| Location | Context |
|---|---|
|
Location of one of Epstein's residences.
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Location of one of Epstein's residences.
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Location of one of Epstein's residences.
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Location of one of Epstein's residences.
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Relationships (2)
Engaged in a single criminal scheme with a common method of operation.
Maxwell exploited young girls using a 'playbook'.
Key Quotes (4)
"The Government cannot be permitted to retry defendants on smaller and smaller conspiracies, wholly contained within the scope of a large conspiracy, until it finds one small enough to be proved to the satisfaction of a jury."Source
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Quote #1
"The second reason that you know that Maxwell is guilty is that she ran the same playbook over and over and over again as she exploited young girls."Source
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Quote #2
"The similarities between what happened to Jane and Annie and Carolyn and Kate are incredibly powerful evidence of the defendant’s guilt."Source
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Quote #3
"The common “playbook” that the government described started by targeting vulnerable kids, like the four accusers, who all came from single-mother households with financial or other hardships."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,241 characters)
Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 28 of 37
of the same overarching conspiracy charged in Counts One and Three, with the same co-
defendants, the same method of operation, and the same objectives. See Macchia, 35 F.3d at 669
(“The Government cannot be permitted to retry defendants on smaller and smaller conspiracies,
wholly contained within the scope of a large conspiracy, until it finds one small enough to be
proved to the satisfaction of a jury.” (citation omitted)).
defendants, the same method of operation, and the same objectives. See Macchia, 35 F.3d at 669
(“The Government cannot be permitted to retry defendants on smaller and smaller conspiracies,
wholly contained within the scope of a large conspiracy, until it finds one small enough to be
proved to the satisfaction of a jury.” (citation omitted)).
2. Similarity of Operation, Common Objectives, and Geographic Scope
The government’s charging theory in the Indictment and its presentation of the evidence
at trial was that Epstein and Maxwell engaged in a single criminal scheme with a common
method of operation to recruit and “groom” underage females to engage in illegal sexual activity
in multiple locations, including Epstein’s residences in New York, Palm Beach, New Mexico,
and the U.S. Virgin Islands. Indeed, in summarizing the evidence for the jury, the government
highlighted that Epstein and Ms. Maxwell used the same “playbook” with all four of the accusers
and argued that this common method of operation was one of the principal reasons that the jury
could convict Ms. Maxwell on all counts:
at trial was that Epstein and Maxwell engaged in a single criminal scheme with a common
method of operation to recruit and “groom” underage females to engage in illegal sexual activity
in multiple locations, including Epstein’s residences in New York, Palm Beach, New Mexico,
and the U.S. Virgin Islands. Indeed, in summarizing the evidence for the jury, the government
highlighted that Epstein and Ms. Maxwell used the same “playbook” with all four of the accusers
and argued that this common method of operation was one of the principal reasons that the jury
could convict Ms. Maxwell on all counts:
The second reason that you know that Maxwell is guilty is that she ran the same
playbook over and over and over again as she exploited young girls. The
similarities between what happened to Jane and Annie and Carolyn and Kate are
incredibly powerful evidence of the defendant’s guilt. So I want to talk to you
about the playbook that Maxwell ran again and again and again.
playbook over and over and over again as she exploited young girls. The
similarities between what happened to Jane and Annie and Carolyn and Kate are
incredibly powerful evidence of the defendant’s guilt. So I want to talk to you
about the playbook that Maxwell ran again and again and again.
Tr. 2848:16-22 (emphasis added); see also Tr. 2853:14-16 (“The patterns you saw throughout
this trial, the playbook that Maxwell ran for years, is just one of the many ways that you know
that Maxwell is guilty.”).
this trial, the playbook that Maxwell ran for years, is just one of the many ways that you know
that Maxwell is guilty.”).
The common “playbook” that the government described started by targeting vulnerable
kids, like the four accusers, who all came from single-mother households with financial or other
hardships. Tr. 2849:18-2850:17. Epstein and Ms. Maxwell then isolated the girls from their
parents and began “grooming” them for sexual abuse by taking an interest in their lives, making
kids, like the four accusers, who all came from single-mother households with financial or other
hardships. Tr. 2849:18-2850:17. Epstein and Ms. Maxwell then isolated the girls from their
parents and began “grooming” them for sexual abuse by taking an interest in their lives, making
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DOJ-OGR-00008952
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