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720 KB
Extraction Summary
8
People
1
Organizations
1
Locations
2
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
720 KB
Summary
This legal document, part of a court filing, argues that Ms. Maxwell's alleged conduct with 'Accuser-3' in England falls outside the scope of the charged conspiracy. It cites the case 'United States v. Hsia' as precedent for distinguishing between a core conspiracy and separate acts of concealment or cover-up. The document contends that the object of the conspiracy was to cause individuals to travel for unlawful acts with Epstein, and Maxwell's interactions with Accuser-3 did not further this specific goal.
People (8)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Mentioned throughout the document in relation to an alleged conspiracy and her conduct with Minor Victim-3 and Accuse...
|
| Minor Victim-3 | Alleged Victim |
Mentioned in the context of Ms. Maxwell's alleged conduct constituting an overt act in furtherance of a conspiracy.
|
| Grunewald |
Party in the legal case citation 'Grunewald v. United States'.
|
|
| Hsia | Defendant |
Defendant in the legal case citation 'United States v. Hsia'.
|
| Epstein | Alleged Co-conspirator |
Mentioned as the person with whom individuals were to engage in unlawful sex acts, and as a co-conspirator with Ms. M...
|
| Accuser-3 | Accuser |
Subject of allegations regarding interactions with Ms. Maxwell in England, which the document argues did not further ...
|
| Accuser-1 | Accuser |
Mentioned as a person that the conspiracy allegedly aimed to cause to travel, and who Accuser-3 did not know.
|
| Accuser-2 | Accuser |
Mentioned as a person that the conspiracy allegedly aimed to cause to travel.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Federal Election Commission | government agency |
Mentioned in the summary of the 'United States v. Hsia' case, where false statements were allegedly made to it.
|
Timeline (2 events)
Alleged conspiracy to cause individuals (Accuser-1, Accuser-2, or anyone else) to travel for unlawful sex acts with Epstein.
Locations (1)
| Location | Context |
|---|---|
|
Location of Ms. Maxwell's interactions with Accuser-3.
|
Relationships (3)
Alleged co-conspirators in a scheme to cause individuals to travel for unlawful sex acts.
The document describes interactions between them in England.
Key Quotes (3)
"the allegations provide little detail about the acts"Source
— The court in United States v. Hsia
(Expressing concern about the indictment in the Hsia case.)
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Quote #1
"references to the alleged acts of concealment and cover-up suggest the inclusion of offenses that are not part of the conspiracy charged in the indictment."Source
— The court in United States v. Hsia
(Expressing concern that acts of concealment were being improperly included in the conspiracy charge.)
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Quote #2
"as to the scope of the alleged conspiratorial agreement and in particular whether and how the acts of concealment alleged in the indictment were within the scope of the conspiracy charged."Source
— The court in United States v. Hsia
(The subject of a bill of particulars ordered by the court to clarify the scope of the conspiracy.)
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,111 characters)
Case 1:20-cr-00330-AJN Document 146 Filed 02/04/21 Page 12 of 16
(quoting Grunewald v. United States, 353 U.S. 391, 397 (1957)). Thus, whether Ms. Maxwell’s
alleged conduct with respect to Minor Victim-3 constituted an overt act in furtherance of the
alleged conspiracy depends on the scope of the alleged conspiracy.
alleged conduct with respect to Minor Victim-3 constituted an overt act in furtherance of the
alleged conspiracy depends on the scope of the alleged conspiracy.
In United States v. Hsia, 24 F. Supp. 2d 14 (D.D.C. 1998), for example, the defendant
was charged with conspiracy, and causing false statements to be made to the Federal Election
Commission, in connection with an alleged scheme to obtain illegal campaign contributions from
foreign donors. The defendant moved to strike references in the indictment to acts of
concealment of the alleged conspiracy. The court expressed concern that “the allegations
provide little detail about the acts” and that “references to the alleged acts of concealment and
cover-up suggest the inclusion of offenses that are not part of the conspiracy charged in the
indictment.” Id. at 25. Although the court denied the defendant’s motion to strike, it ordered a
bill of particulars “as to the scope of the alleged conspiratorial agreement and in particular
whether and how the acts of concealment alleged in the indictment were within the scope of the
conspiracy charged.” Id. at 33. The court added that if the bill of particulars confirmed the
defendant’s assertion that the alleged acts of concealment and cover-up were not within the
alleged scope of the conspiratorial agreement, her motion to strike would be granted. Id. at 26.
was charged with conspiracy, and causing false statements to be made to the Federal Election
Commission, in connection with an alleged scheme to obtain illegal campaign contributions from
foreign donors. The defendant moved to strike references in the indictment to acts of
concealment of the alleged conspiracy. The court expressed concern that “the allegations
provide little detail about the acts” and that “references to the alleged acts of concealment and
cover-up suggest the inclusion of offenses that are not part of the conspiracy charged in the
indictment.” Id. at 25. Although the court denied the defendant’s motion to strike, it ordered a
bill of particulars “as to the scope of the alleged conspiratorial agreement and in particular
whether and how the acts of concealment alleged in the indictment were within the scope of the
conspiracy charged.” Id. at 33. The court added that if the bill of particulars confirmed the
defendant’s assertion that the alleged acts of concealment and cover-up were not within the
alleged scope of the conspiratorial agreement, her motion to strike would be granted. Id. at 26.
Here, the object of the alleged conspiracies—necessarily, under the Mann Act—was not
to cause any individual to engage in unlawful sex acts with Epstein, but to cause individuals to
travel to do so. The allegations regarding Accuser-3, even if proven, could not have furthered
such alleged conspiracies. There is no basis for any reasonable inference that Epstein and Ms.
Maxwell’s interactions with Accuser-3 in England furthered a conspiracy to cause Accuser-1,
Accuser-2, or anyone else to travel. There is no allegation that Accuser-3 even knew Accuser-1
to cause any individual to engage in unlawful sex acts with Epstein, but to cause individuals to
travel to do so. The allegations regarding Accuser-3, even if proven, could not have furthered
such alleged conspiracies. There is no basis for any reasonable inference that Epstein and Ms.
Maxwell’s interactions with Accuser-3 in England furthered a conspiracy to cause Accuser-1,
Accuser-2, or anyone else to travel. There is no allegation that Accuser-3 even knew Accuser-1
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