DOJ-OGR-00008590.jpg
691 KB
Extraction Summary
6
People
1
Organizations
6
Locations
5
Events
5
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
691 KB
Summary
This document is a page from jury instructions (Instruction No. 36) in a federal criminal case, filed on December 18, 2021. It details the 'overt act' element required to prove a conspiracy charge, listing specific allegations from the indictment against conspirators Maxwell and Epstein. The alleged overt acts, occurring between 1994 and 2002, involve the sexual abuse and exploitation of underage victims identified as Jane, Annie, Kate, and Carolyn across multiple locations including New York, Florida, New Mexico, and London.
People (6)
| Name | Role | Context |
|---|---|---|
| Jane | Victim |
Alleged victim in overt acts for Count One. Mentioned as being under the age of 17/18 during sexual encounters with M...
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| Maxwell | Conspirator/Defendant |
Alleged conspirator who participated in group sexual encounters, provided an unsolicited massage, encouraged another ...
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| Epstein | Conspirator |
Alleged conspirator who participated in group sexual encounters, was the intended recipient of massages from a minor,...
|
| Annie | Victim |
Alleged victim who, while under 18, was given an unsolicited massage by Maxwell in New Mexico.
|
| Kate | Victim |
Alleged victim who, while under 18, was encouraged by Maxwell to provide massages to Epstein in London.
|
| Carolyn | Victim |
Alleged victim who, while under 18, was invited by Maxwell and Epstein to travel from Florida.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Government | Government agency |
The prosecuting party that must prove the elements of the conspiracy charge.
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Timeline (5 events)
Locations (6)
| Location | Context |
|---|---|
|
Location of alleged group sexual encounters involving Maxwell, Epstein, and Jane. Destination for Jane's travel for t...
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Location of alleged group sexual encounters involving Maxwell, Epstein, and Jane. Origin of travel for Jane and Carolyn.
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Location where Jane was allegedly to be sexually abused.
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Location where Maxwell allegedly provided an unsolicited massage to Annie.
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Location where Maxwell allegedly encouraged Kate to provide massages to Epstein.
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Location where Maxwell allegedly encouraged Kate to provide massages to Epstein.
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Relationships (5)
The document lists them as 'conspirators' and describes several overt acts they allegedly committed together in furtherance of a conspiracy, such as participating in group sexual encounters and inviting a minor to travel.
Maxwell allegedly participated in group sexual encounters with Jane when Jane was a minor.
Maxwell allegedly provided an unsolicited massage to Annie when Annie was a minor.
Maxwell allegedly encouraged Kate, a minor, to provide massages to Epstein for the purpose of sexual abuse.
Full Extracted Text
Complete text extracted from the document (1,965 characters)
Case 1:20-cr-00330-PAE Document 563 Filed 12/18/21 Page 52 of 167
1 Instruction No. 36: Counts One, Three, and Five Two: Conspiracy to Violate Federal Law
2 – Third Element
2 – Third Element
3 The third element that the Government must prove beyond a reasonable doubt to
4 establish the offense of conspiracy is that at least one overt act was knowingly committed by at
5 least one of the conspirators.
4 establish the offense of conspiracy is that at least one overt act was knowingly committed by at
5 least one of the conspirators.
6 The overt act element requires the Government to show something more than mere
7 agreement; some overt step or action must have been taken by at least one of the conspirators in
8 furtherance of that conspiracy. In other words, the Government must show that the agreement
9 went beyond the mere talking stage. It must show that at least one of the conspirators actually
10 did something in furtherance of the conspiracy.
7 agreement; some overt step or action must have been taken by at least one of the conspirators in
8 furtherance of that conspiracy. In other words, the Government must show that the agreement
9 went beyond the mere talking stage. It must show that at least one of the conspirators actually
10 did something in furtherance of the conspiracy.
11 With respect to the overt acts for Count One, the Indictment reads-alleges as follows:
12 (1) Between in or about 1994 and in or about 1997, when Jane was under the age of 1718,
13 Maxwell participated in multiple group sexual encounters with Epstein and Jane in New York
14 and Florida; (2) In or about 1996, when Jane was under the age of 178, Jane was enticed to travel
15 from Florida to New York for purposes of sexually abusing her at the New York Residence, in
16 violation of New York Penal Law, Section 130.55; (3) In or about 1996, when Annie was under
17 the age of 18, Maxwell provided Annie with an unsolicited massage in New Mexico, during
18 which Annie was topless; (4) Between in or about 1994 and in or about 1995, when Kate was
19 under the age of 18, Maxwell encouraged Kate to provide massages to Epstein in London,
20 England, knowing that Epstein intended to sexually abuse Kate during those massages; (45)
21 Between in or about 2001 and in or about 2002, when Carolyn was under the age of 178,
22 Maxwell and Epstein invited Carolyn to travel from Florida to a place outside of Florida with
23 Epstein.
13 Maxwell participated in multiple group sexual encounters with Epstein and Jane in New York
14 and Florida; (2) In or about 1996, when Jane was under the age of 178, Jane was enticed to travel
15 from Florida to New York for purposes of sexually abusing her at the New York Residence, in
16 violation of New York Penal Law, Section 130.55; (3) In or about 1996, when Annie was under
17 the age of 18, Maxwell provided Annie with an unsolicited massage in New Mexico, during
18 which Annie was topless; (4) Between in or about 1994 and in or about 1995, when Kate was
19 under the age of 18, Maxwell encouraged Kate to provide massages to Epstein in London,
20 England, knowing that Epstein intended to sexually abuse Kate during those massages; (45)
21 Between in or about 2001 and in or about 2002, when Carolyn was under the age of 178,
22 Maxwell and Epstein invited Carolyn to travel from Florida to a place outside of Florida with
23 Epstein.
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DOJ-OGR-00008590
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