EFTA00023049.pdf
177 KB
Extraction Summary
5
People
1
Organizations
3
Locations
4
Events
4
Relationships
5
Quotes
Document Information
Type:
Legal request (list of particulars)
File Size:
177 KB
Summary
This document is a 'List of Particulars' (Exhibit A), likely filed by the defense for Ghislaine Maxwell. It contains 29 specific requests demanding the government provide precise dates, locations, and details regarding allegations of sexual abuse, grooming, and interstate travel involving three minor victims between 1994 and 1997. It also requests specifics regarding perjury allegations related to depositions in 2016.
People (5)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Subject of the indictment; alleged to have groomed victims and facilitated abuse.
|
| Jeffrey Epstein | Alleged Abuser |
Alleged to have sexually abused minor victims and conspired with Maxwell.
|
| Minor Victim-1 | Alleged Victim |
Alleged to have been abused, groomed, and traveled across state lines (Florida to NY).
|
| Minor Victim-2 | Alleged Victim |
Alleged to have been abused, groomed, and traveled to/from New Mexico.
|
| Minor Victim-3 | Alleged Victim |
Alleged to have been abused, groomed, and introduced to Epstein by Maxwell.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Government |
The prosecution, to whom these requests for particulars are addressed.
|
Timeline (4 events)
1994-1997
Time period of the charged conspiracies
Interstate/Foreign Commerce
1996
Minor Victim-2 allegedly traveled across state lines to and from New Mexico
New Mexico
1996
Locations (3)
| Location | Context |
|---|---|
|
Location Minor Victim-2 allegedly traveled to and from in 1996.
|
|
|
Origin location for Minor Victim-1's travel in 1996.
|
|
|
Destination location for Minor Victim-1's travel in 1996.
|
Relationships (4)
Charged conspiracies in Count One and Count Three; participation in 'group sexualized encounters'.
Allegedly groomed victim, was present for abuse, participated in massages.
Allegedly groomed victim, engaged in unsolicited massage.
Allegedly introduced victim to Epstein, groomed victim.
Key Quotes (5)
"Please identify the dates when, and locations where, Ms. Maxwell allegedly 'groomed' Minor Victim-1 'to engage in sexual acts with Epstein'"Source
EFTA00023049.pdf
Quote #1
"Please identify the dates when Minor Victim-2 allegedly traveled across state lines to and from New Mexico in 1996"Source
EFTA00023049.pdf
Quote #2
"Please describe with particularity the conduct that the government believes constitutes a 'group sexualized encounter'"Source
EFTA00023049.pdf
Quote #3
"Please identify who allegedly enticed Minor Victim-1 to travel from Florida to New York in 1996"Source
EFTA00023049.pdf
Quote #4
"Please identify from whom Ms. Maxwell was allegedly trying to 'conceal her crimes' when she allegedly lied under oath in depositions in 2016"Source
EFTA00023049.pdf
Quote #5
Full Extracted Text
Complete text extracted from the document (4,970 characters)
Exhibit A
EFTA00023049
EFTA00023049
LIST OF PARTICULARS
1. Please provide the full names and full birthdays of the individuals identified in the Superseding Indictment as Minor Victims-1-3 (¶¶ 7, 11, 13, 17, 19).
2. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or interacted with Minor Victim-1 (¶ 7a).
3. Please identify the dates when, and locations where, Ms. Maxwell allegedly “groomed” Minor Victim-1 “to engage in sexual acts with Epstein” (¶ 7a).
4. Please identify the dates when, and locations where, Jeffrey Epstein allegedly sexually abused Minor Victim-1 (¶ 7a).
5. Please identify the dates when, and locations where, Ms. Maxwell allegedly “was present for and involved in” Epstein’s sexual abuse of Minor Victim-1 (¶ 7a).
6. Please identify the dates when, and locations where, Minor Victim-1 participated in “group sexualized massages” of Epstein (¶ 7a).
7. Please describe with particularity the conduct that the government contends is a “group sexualized massage” and identify the criminal statute(s) the conduct allegedly violates and the other participants in those massages (¶ 7a).
8. Please describe with particularity how Ms. Maxwell allegedly “involved” Minor Victim-1 in these massages and how Ms. Maxwell allegedly participated in these massages (¶ 7a).
9. Please identify the dates when Minor Victim-1 allegedly traveled “across state lines for the purpose of sexual encounters with Epstein” (¶ 7a).
10. Please identify the dates when Ms. Maxwell allegedly enticed Minor Victim-1 “to travel across state lines for the purpose of sexual encounters with Epstein” and describe with particularity the actions that Ms. Maxwell allegedly took to entice Minor Victim-1 to travel (¶ 7a).
11. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or interacted with Minor Victim-2 (¶ 7b).
12. Please identify the dates when Minor Victim-2 allegedly traveled across state lines to and from New Mexico in 1996 (¶ 7b).
13. Please identify the dates when Ms. Maxwell allegedly “groomed” Minor Victim-2 to engage in “acts of sexual abuse” with Epstein (¶ 7b).
EFTA00023050
EFTA00023050
14. Please describe with particularity what Ms. Maxwell allegedly did as part of the “unsolicited massage” of Minor Victim-2 and identify the criminal statute(s) the conduct allegedly violates (¶ 7b, 11c, 17c).
15. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or interacted with Minor Victim-3 (¶ 7c).
16. Please identify the dates when, and locations where, Ms. Maxwell allegedly introduced Minor Victim-3 to Epstein and the dates and locations of their subsequent “multiple interactions” (¶ 7c).
17. Please identify the dates when, and locations where, Ms. Maxwell allegedly “groomed” Minor Victim-3 to engage in sex acts with Epstein (¶ 7c).
18. Please identify the dates when, and locations where, Jeffrey Epstein allegedly sexually abused Minor Victim-3 (¶ 7c).
19. Please describe with particularity the “sex acts” that Minor Victim-3 allegedly engaged in with Epstein during massages and identify the criminal statute(s) the conduct allegedly violates and the other participants in those massages (¶ 7c).
20. Please identify the dates when Minor Victim-3 allegedly traveled in interstate or foreign commerce to engage in illegal sexual activity with Epstein (¶ 7c).
21. Please specify when the conspiracies charged in Count One and Count Three began and ended. (¶¶ 9, 15).
22. Please identify the “others” who allegedly participated in the conspiracies charged in Count One and Count Three with Epstein and Ms. Maxwell. (¶¶ 9-10, 15-16).
23. Please identify any individuals who were enticed to travel, or were transported, in interstate or foreign commerce to engage in illegal sexual activity with Epstein during the time period of the charged conspiracies (1994-1997), apart from Minor Victims-1-3 (¶ 10, 16).
24. Please identify the dates when, and the locations where, Ms. Maxwell participated in “group sexualized encounters” with Jeffrey Epstein and Minor Victim-1 (¶¶ 11a, 17a).
25. Please describe with particularity the conduct that the government believes constitutes a “group sexualized encounter” and identify the criminal statute(s) the conduct violates and the participants in those encounters (¶¶ 11a, 17a).
26. Please identify who allegedly enticed Minor Victim-1 to travel from Florida to New York in 1996 (¶¶ 11b, 17b).
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EFTA00023051
27. Please identify from whom Ms. Maxwell was allegedly trying to “conceal her crimes” when she allegedly lied under oath in depositions in 2016 (¶ 2).
28. Please identify “the specific events and acts of abuse” about which Ms. Maxwell allegedly “repeatedly provided false and perjurious statements” (¶ 8).
29. As to each statement alleged to be perjurious in Counts Five and Six of the Superseding Indictment please specify why the Government contends the statement was material (¶¶ 21, 23).
EFTA00023052
EFTA00023052
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