DOJ-OGR-00014624.jpg

624 KB

Extraction Summary

3
People
2
Organizations
3
Locations
3
Events
3
Relationships
1
Quotes

Document Information

Type: Legal document
File Size: 624 KB
Summary

This legal document outlines specific actions taken between 2001 and 2004 as part of a conspiracy charge. It details how Jeffrey Epstein, Ghislaine Maxwell, and other employees sent gifts (including lingerie) to a woman named Carolyn and repeatedly called her to schedule massages for Epstein. The document concludes with a legal clarification that for a conspiracy conviction, it is sufficient to prove that any member of the conspiracy committed an overt act, not necessarily the defendant (Ms. Maxwell) herself.

People (3)

Name Role Context
Epstein Employer
Mentioned as the person whose employees sent gifts, who caused a package to be sent, and for whom massages were sched...
Carolyn
Recipient of gifts and packages, and was called to provide massages for Epstein.
Maxwell Employee of Epstein
Mentioned as one of the individuals who called Carolyn to schedule an appointment. Also referred to as 'Ms. Maxwell' ...

Organizations (2)

Name Type Context
Federal Express Company
Used to send a package from Manhattan to Carolyn in Florida.
SOUTHERN DISTRICT REPORTERS, P.C. Company
Listed at the bottom of the document, likely the court reporting agency.

Timeline (3 events)

2001-2004
Epstein's employees sent Carolyn gifts, including lingerie, from the Southern District of New York to her residence in Florida.
Southern District of New York to Florida
Epstein's employees Carolyn
2001-2004
On multiple occasions, Epstein, Maxwell, or other employees called Carolyn to schedule appointments for her to massage Epstein.
Epstein Maxwell Epstein's other employees Carolyn
2002-10
Epstein caused a package to be sent by Federal Express from Manhattan to Carolyn in Florida.
Manhattan to Florida

Locations (3)

Location Context
The location from which gifts were sent to Carolyn.
Location of Carolyn's residence, where gifts and a package were sent.
The origin of a package sent by Federal Express to Carolyn.

Relationships (3)

Epstein Professional/Client Carolyn
Epstein's employees sent gifts to Carolyn, and she was called on multiple occasions to massage Epstein.
Epstein Employer-Employee Maxwell
The document states Maxwell was 'one of Epstein's other employees' who called Carolyn on his behalf.
Maxwell Professional Interaction Carolyn
Maxwell called Carolyn to schedule an appointment for Carolyn to massage Epstein.

Key Quotes (1)

"In order for government to satisfy this element, it's not necessary for the government to prove that Ms. Maxwell committed the overt act."
Source
— Unnamed (likely prosecutor or judge) (Part of a legal explanation of the requirements to prove a conspiracy charge, stating that the defendant (Ms. Maxwell) did not personally have to commit the overt act.)
DOJ-OGR-00014624.jpg
Quote #1

Full Extracted Text

Complete text extracted from the document (1,581 characters)

Case 1:20-cr-00330-PAE Document 767 Filed 08/10/22 Page 224 of 257 3058
LCKCmax9
Charge
1 which she did.
2 Three, between in or about 2001 and in or about 2004,
3 Epstein's employees sent Carolyn gifts, including lingerie from
4 an address in the Southern District of New York to Carolyn's
5 residence in Florida. For example, on one occasion, in or
6 about October of 2002, Epstein caused a package to be sent by
7 Federal Express from an address in Manhattan to Carolyn in
8 Florida.
9 Four, on multiple occasions between in or about 2001
10 and in or about 2004, Epstein, Maxwell, or one of Epstein's
11 other employees called Carolyn to schedule an appointment for
12 Carolyn to massage Epstein. For example, in or about April of
13 2004 or May of 2004, another employee of Epstein's called
14 Carolyn to schedule such appointments.
15 In order for government to satisfy this element, it's
16 not necessary for the government to prove that Ms. Maxwell
17 committed the overt act. It is sufficient for the government
18 to show that any of the members of the conspiracy knowingly
19 committed some overt act in furtherance of the conspiracy.
20 Further, the overt act need not be one that is alleged
21 in the indictment. Rather, it can be any overt act that is
22 substantially similar to those acts alleged in the indictment,
23 if you are convinced that the act occurred while the conspiracy
24 was still in existence and that it was done in furtherance of
25 the conspiracy as described in the indictment.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00014624

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