DOJ-OGR-00008942.jpg
732 KB
Extraction Summary
3
People
0
Organizations
9
Locations
5
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
732 KB
Summary
This legal document, part of a court filing, argues that Ms. Maxwell's conviction on Count Four was likely improper. The argument centers on a note from the jury, which suggests they based the conviction on sexual abuse that victim 'Jane' experienced in New Mexico, facilitated by Maxwell. However, the charge required the intended sexual activity to be a violation of New York Penal Law, a condition the New Mexico events did not satisfy.
People (3)
| Name | Role | Context |
|---|---|---|
| Jane | Witness/Victim |
A witness whose testimony is central to Count Four, detailing travel and sexual abuse by Epstein, facilitated by Ms. ...
|
| Epstein | Perpetrator |
Mentioned as the individual who sexually abused Jane in his residences in Palm Beach, New York, and New Mexico.
|
| Ms. Maxwell | Defendant |
The defendant in the case, accused of facilitating Jane's travel for the purpose of sexual abuse. The document discus...
|
Timeline (5 events)
Jane traveled with Epstein and Ms. Maxwell from Florida to New York.
from Florida to New York
Jane traveled to New Mexico with Epstein and Ms. Maxwell when she was 15 or 16.
New Mexico
Locations (9)
| Location | Context |
|---|---|
|
Mentioned as the origin of travel to New York.
|
|
|
A destination for travel from Florida and the location of one of Epstein's residences where Jane was abused.
|
|
|
Location of Epstein's house where Jane testified she was sexually abused.
|
|
|
Location of one of Epstein's residences and the jurisdiction whose penal law is relevant to the charge.
|
|
|
Location of Epstein's ranch where Jane testified she was flown to and sexually abused.
|
|
|
Site of sexual abuse testified to by Jane.
|
|
|
Sites where Jane was sexually abused.
|
|
|
Site of sexual abuse testified to by Jane.
|
|
|
Location in New Mexico where Jane stayed and was sexually abused.
|
Relationships (3)
Jane testified that she traveled with Ms. Maxwell and Epstein on trips during which she was sexually abused by Epstein.
Jane testified that Epstein sexually abused her at his properties in Palm Beach, New York, and New Mexico.
They traveled together with Jane on trips where Jane was sexually abused by Epstein.
Key Quotes (4)
"from Florida to New York, New York,"Source
— Unknown
(Describing the travel that was the subject of a defense request regarding language in the case.)
DOJ-OGR-00008942.jpg
Quote #1
"15 or 16."Source
— Jane
(Jane's recollection of her age during a trip to New Mexico.)
DOJ-OGR-00008942.jpg
Quote #2
"sexual activity in violation of New York Penal Law, Section 130.55"Source
— Unknown
(The legal standard for the conduct in Count Four, which the document argues was not met by the events in New Mexico.)
DOJ-OGR-00008942.jpg
Quote #3
"Under Count Four (4), if the defendant aided in the transportation of Jane’s return flight, but not the flight to New Mexico where/if the intent was for Jane to engage in sexual activity, can she be found guilty under the second element?"Source
— Jury
(A question from the Jury Note, cited as evidence that the jury improperly based their conviction on events in New Mexico.)
DOJ-OGR-00008942.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,161 characters)
Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 18 of 37
was travel “from Florida to New York, New York,” despite the defense’s request to include that language. Dkt. 410-1 at 19; Tr. 2758:23-2760:9.
The evidence at trial concerning Count Four rested exclusively on the testimony of Jane and evidence that corroborated her testimony. Jane testified primarily about being sexually abused by Epstein in Epstein’s house in Palm Beach. Tr. 298:16-315:19. Jane also testified that she traveled several times with Epstein and Ms. Maxwell when she was 14, 15 and 16 and was sexually abused in Epstein’s residences in New York and New Mexico. Tr. 316:2-324:20. As most of these trips were to New York, the majority of Jane’s testimony about the trips consisted of a description of Epstein’s house in New York and the sexual abuse she experienced there. Tr. 317:2-321:5. But Jane did recall one trip to New Mexico when she was “15 or 16.” Tr. 321:6-321:13. Jane testified that she flew to New Mexico with Epstein and Ms. Maxwell and stayed at Epstein’s ranch. Tr. 321:14-322:6. She further testified that, at some point while she was there, someone came to her room and escorted her to Epstein’s room where she was sexually abused. Tr. 322:7-323:19.
Based on this testimony and the text of the Jury Note, there is a substantial likelihood that the jury did not convict Ms. Maxwell based on Jane’s testimony about the New York trips, and instead improperly based their conviction solely on the sexual abuse that Jane experienced in New Mexico. According to the Jury Note, the jurors had the mistaken impression that it would be sufficient to satisfy the second element of Count Four if they found that Ms. Maxwell had intended Jane to engage in sexual activity in New Mexico, even though such conduct was not and could not have been “sexual activity in violation of New York Penal Law, Section 130.55”:
Under Count Four (4), if the defendant aided in the transportation of Jane’s return flight, but not the flight to New Mexico where/if the intent was for Jane to engage in sexual activity, can she be found guilty under the second element?
The evidence at trial concerning Count Four rested exclusively on the testimony of Jane and evidence that corroborated her testimony. Jane testified primarily about being sexually abused by Epstein in Epstein’s house in Palm Beach. Tr. 298:16-315:19. Jane also testified that she traveled several times with Epstein and Ms. Maxwell when she was 14, 15 and 16 and was sexually abused in Epstein’s residences in New York and New Mexico. Tr. 316:2-324:20. As most of these trips were to New York, the majority of Jane’s testimony about the trips consisted of a description of Epstein’s house in New York and the sexual abuse she experienced there. Tr. 317:2-321:5. But Jane did recall one trip to New Mexico when she was “15 or 16.” Tr. 321:6-321:13. Jane testified that she flew to New Mexico with Epstein and Ms. Maxwell and stayed at Epstein’s ranch. Tr. 321:14-322:6. She further testified that, at some point while she was there, someone came to her room and escorted her to Epstein’s room where she was sexually abused. Tr. 322:7-323:19.
Based on this testimony and the text of the Jury Note, there is a substantial likelihood that the jury did not convict Ms. Maxwell based on Jane’s testimony about the New York trips, and instead improperly based their conviction solely on the sexual abuse that Jane experienced in New Mexico. According to the Jury Note, the jurors had the mistaken impression that it would be sufficient to satisfy the second element of Count Four if they found that Ms. Maxwell had intended Jane to engage in sexual activity in New Mexico, even though such conduct was not and could not have been “sexual activity in violation of New York Penal Law, Section 130.55”:
Under Count Four (4), if the defendant aided in the transportation of Jane’s return flight, but not the flight to New Mexico where/if the intent was for Jane to engage in sexual activity, can she be found guilty under the second element?
13
DOJ-OGR-00008942
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document