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696 KB

Extraction Summary

3
People
0
Organizations
2
Locations
4
Events
2
Relationships
4
Quotes

Document Information

Type: Legal document
File Size: 696 KB
Summary

This legal document, part of an appeal (Case 22-1426), argues against Ghislaine Maxwell's interpretation of a jury note from her trial. The prosecution contends the jury's question about her guilt based on events in New Mexico was a valid inquiry into her intent, not a misunderstanding of the law. The document also refutes Maxwell's claim of insufficient evidence regarding her arrangement of a victim's (Jane's) return flight from New Mexico, suggesting the jury could have reasonably convicted her on that basis despite a lack of specific documentary proof.

People (3)

Name Role Context
Maxwell Defendant
Mentioned throughout the document as the subject of the legal arguments, accused of transporting 'Jane' and arranging...
Jane Victim/Witness
Mentioned as the person who was transported, experienced sexual abuse, and whose travel to New York and return flight...
Judge Nathan Judge
Mentioned as the judge at the trial to whom defense counsel raised a question.

Timeline (4 events)

The trial of Maxwell, where Jane testified, defense counsel raised questions to Judge Nathan, and the jury deliberated and sent a note.
Maxwell Jane Judge Nathan defense counsel jury
Jane's travel to New York, which was followed by sexual abuse.
New York
Sexual activity and abuse involving Jane occurred.
New Mexico
An unidentified commercial return flight from New Mexico for Jane, which Maxwell allegedly arranged after the sexual abuse.
New Mexico

Locations (2)

Location Context
Location where sexual activity occurred and from which a return flight for 'Jane' was allegedly arranged by Maxwell.
Destination of 'Jane's' travel where ensuing sexual abuse occurred.

Relationships (2)

Maxwell Criminal/Exploitative Jane
The document discusses Maxwell's alleged role in transporting Jane for the purpose of sexual abuse and arranging her travel.
defense counsel Professional Judge Nathan
The document states that the defense counsel repeatedly raised a question to Judge Nathan during the trial.

Key Quotes (4)

"significant or motivating purpose"
Source
— Legal argument (Used to describe the legal standard for prostitution in relation to interstate transportation.)
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Quote #1
"can be found guilty"
Source
— Jury (Part of a question from the jury to the court regarding Maxwell's guilt if a certain fact is true.)
DOJ-OGR-00021734.jpg
Quote #2
"[T]he jury likely believed that if they found Maxwell had some role in arranging Jane's return flight from New Mexico, after the sexual abuse had already taken place, they could convict her on the substantive transportation count . . ."
Source
— Author of brief (Br.79-80) (A quote from a legal brief speculating on the jury's reasoning for conviction.)
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Quote #3
"no evidence"
Source
— Defense (Part of the defense argument stating there was no evidence Maxwell arranged a return flight from New Mexico (Tr.3133).)
DOJ-OGR-00021734.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,841 characters)

Case 22-1426, Document 79, 06/29/2023, 3536060, Page87 of 93
74
prostitution must be a “significant or motivating pur-
pose” of the interstate transportation). Maxwell only
came to the theory she now advances after a lengthy
discussion spanning ten pages of the transcript.
(A.387). And that reading is far from clear: the jury’s
question does not ask whether certain facts are suffi-
cient for guilt; it asks whether Maxwell “can be found
guilty” if a certain fact is true. Maxwell “can” be found
guilty based in part on sexual activity occurring in
New Mexico, which is probative of Maxwell’s intent
and role in transporting Jane. That is a perfectly sen-
sible question for the jury to ask—indeed, it was re-
peatedly raised by defense counsel to Judge Nathan at
trial. (See, e.g., Tr.3149).
Setting aside the jury note, Maxwell’s position re-
quires the jury to have reached a series of odd conclu-
sions. Jane testified at length about her travel to New
York and the ensuing sexual abuse there. It would
make little sense for the jury to reject that testimony,
and then conclude that Maxwell arranged the uniden-
tified commercial return flight Maxwell now empha-
sizes, for which there is no documentary evidence in
the record, including no specific corroboration of Max-
well’s role in arranging that flight. (Compare Br.79-80
(“[T]he jury likely believed that if they found Maxwell
had some role in arranging Jane’s return flight from
New Mexico, after the sexual abuse had already taken
place, they could convict her on the substantive trans-
portation count . . .”) with Tr.3133 (defense argument
that there is “no evidence” Maxwell arranged a return
flight from New Mexico)). Maxwell suggests that the
jury thought the flight records to be critical evidence,
but the flight logs also demonstrate that Jane was
DOJ-OGR-00021734

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