DOJ-OGR-00002680.jpg
737 KB
Extraction Summary
8
People
2
Organizations
3
Locations
4
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
737 KB
Summary
This document is a preliminary statement from a legal motion filed on behalf of Ghislaine Maxwell on February 4, 2021. The defense requests that the Court strike allegations related to 'Accuser-3' from the indictment, arguing that the alleged conduct occurred in England where Accuser-3 was above the age of consent and did not involve travel. The motion claims the government is improperly using these allegations to bolster its case regarding Mann Act violations involving 'Accuser-1' and Jeffrey Epstein.
People (8)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
The subject of the indictment and the person submitting the motion to strike surplusage from the indictment.
|
| Accuser-3 | Alleged Victim / Witness |
An individual whose allegations the defense wants stricken from the indictment, arguing she was above the age of cons...
|
| Accuser-1 | Alleged Victim |
An individual Ms. Maxwell is alleged to have enticed and/or transported from Florida to New York for sexual encounter...
|
| Jeffrey Epstein | Co-conspirator (implied) |
Mentioned as a participant in alleged group sexual encounters with Ms. Maxwell and Accuser-1.
|
| Accuser-2 | Alleged Victim |
Mentioned in a footnote as an individual identified in the indictment, also referred to as Minor Victim-2.
|
| Minor Victim-3 | Alleged Victim |
Alias for Accuser-3, as stated in a footnote.
|
| Minor Victim-1 | Alleged Victim |
Alias for Accuser-1, as stated in a footnote.
|
| Minor Victim-2 | Alleged Victim |
Alias for Accuser-2, as stated in a footnote.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Court | government agency |
The judicial body being addressed in the motion to strike allegations from the indictment.
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| government | government agency |
The prosecuting party, accused by the defense of a 'transparent attempt' to introduce Accuser-3's testimony.
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Timeline (4 events)
Ms. Maxwell allegedly enticed or caused Accuser-1 to travel from Florida to New York for the purpose of engaging in sexual encounters with Epstein.
Between Florida and New York
between 1994 and 1997
Alleged violations of the Mann Act by Ghislaine Maxwell, including enticement and transportation of individuals for unlawful sexual activity.
Locations (3)
| Location | Context |
|---|---|
|
The location where all alleged conduct regarding Accuser-3 took place, and where she was reportedly above the legal a...
|
|
|
The state from which Accuser-1 was allegedly enticed or caused to travel.
|
|
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The destination to which Accuser-1 allegedly traveled for the purpose of engaging in sexual encounters.
|
Relationships (3)
The document alleges Ms. Maxwell engaged in group sexual encounters with Jeffrey Epstein and Accuser-1, and caused Accuser-1 to travel to engage in encounters with Epstein.
The indictment alleges Maxwell enticed and/or transported Accuser-1 from Florida to New York for unlawful sexual activity.
The document discusses allegations of conduct between Maxwell and Accuser-3 in England, which the defense argues should be stricken from the indictment.
Full Extracted Text
Complete text extracted from the document (2,172 characters)
Case 1:20-cr-00330-AJN Document 146 Filed 02/04/21 Page 5 of 16
PRELIMINARY STATEMENT
Ghislaine Maxwell respectfully submits this Memorandum in Support of her Motion to Strike Surplusage from the Indictment (“Motion”).
Although Ms. Maxwell is charged with conspiring to cause individuals to travel in interstate or foreign commerce to engage in unlawful sexual activity, the indictment contains no allegation that Accuser-3 ever traveled.¹ Moreover, throughout the period alleged in the indictment, Accuser-3 was above the legal age of consent in England, where all alleged conduct as to her took place. Therefore, the Court should strike all allegations regarding Accuser-3 from the indictment, as they are nothing more than a transparent attempt by the government to introduce Accuser-3’s testimony as evidence of a conspiracy, when it is at most “other acts” evidence subject to the balancing test required by Fed. R. Evid. 404(b).
Counts One through Four of the indictment allege that between 1994 and 1997, Ms. Maxwell violated and conspired to violate two separate provisions of the Mann Act: 18 U.S.C. § 2422 (now § 2422(a)), which prohibits the enticement of individuals to travel in interstate or foreign commerce for the purpose of engaging in unlawful sexual activity, and 18 U.S.C. § 2423(a), which prohibits the transportation of individuals under age 18 in interstate or foreign commerce with the intent that they engage in unlawful sexual activity. The substantive Mann Act counts involve Ms. Maxwell’s alleged enticement and/or transportation of Accuser-1.
The indictment alleges that Ms. Maxwell engaged in group sexual encounters with Jeffrey Epstein and Accuser-1 and that, on at least one occasion, Ms. Maxwell enticed or caused Accuser-1 to travel from Florida to New York for the purpose of engaging in such encounters with Epstein. But to do so, it must rely on the accusations of a single individual regarding
¹ This individual is described in the indictment as Minor Victim-3. Similarly, we refer to the individuals identified in the indictment as Minor Victim-1 and Minor Victim-2 as Accuser-1 and Accuser-2, respectively.
DOJ-OGR-00002680
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