DOJ-OGR-00021900.jpg

633 KB

Extraction Summary

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

Document Information

Type: Legal document
File Size: 633 KB
Summary

This legal document page addresses two arguments from the defendant, Maxwell. First, it refutes her claim of 'substantial prejudice' from evidence of her conduct in New Mexico, noting she received the evidence weeks before trial. Second, it introduces Maxwell's argument that her sentence was procedurally unreasonable due to a leadership enhancement, an argument the court states it will disagree with.

People (4)

Name Role Context
Maxwell Defendant
The central figure in the document, arguing against her conviction and sentence. She is alleged to have transported '...
Jane Victim
A victim who was transported to New York by Maxwell for sexual abuse and also suffered abuse in New Mexico.
Epstein Co-conspirator
Mentioned in a footnote as having groomed victims for abuse with the Defendant (Maxwell) at various properties, inclu...
Lebedev Defendant in a cited case
Mentioned in the case citation 'United States v. Lebedev' regarding prejudice.

Organizations (3)

Name Type Context
District Court government agency
The court that handled Maxwell's trial and sentencing, which is being reviewed.
United States government agency
Mentioned in the case citation 'United States v. Lebedev'.
2d Cir. government agency
The United States Court of Appeals for the Second Circuit, mentioned in a case citation.

Timeline (4 events)

Maxwell transported Jane to New York for sexual abuse.
New York
Jane suffered sexual abuse.
New Mexico
Maxwell's criminal trial, where she received evidence (notes of Jane's interview) over three weeks prior.
District Court
The District Court sentenced Maxwell to 240 months' imprisonment, a term slightly above the Guidelines range of 188 to 235 months.
District Court

Locations (3)

Location Context
Location where Maxwell transported Jane for sexual abuse and where the Indictment charged a scheme to sexually abuse ...
Location where Maxwell's conduct also occurred and where Jane suffered abuse at Epstein's ranch.
A specific location mentioned in a footnote where victims were groomed for abuse.

Relationships (2)

Maxwell perpetrator-victim Jane
The document states that 'Maxwell transported Jane to New York for sexual abuse and conspired to do the same.'
Maxwell co-conspirators Epstein
A footnote quotes the District Court finding that 'Epstein and the Defendant [Maxwell] groomed the victims for abuse'.

Key Quotes (3)

"materially different"
Source
— Maxwell (argument) (Describing the evidence of conduct in New Mexico compared to the allegations in the Indictment.)
DOJ-OGR-00021900.jpg
Quote #1
"substantial prejudice."
Source
— Maxwell (argument) (What Maxwell cannot demonstrate regarding the evidence presented against her.)
DOJ-OGR-00021900.jpg
Quote #2
"[t]he Indictment charged a scheme to sexually abuse underage girls in New York. In service of this scheme, the Indictment alleged that Epstein and the Defendant groomed the victims for abuse at various properties and in various states, including Epstein’s ranch in New Mexico."
Source
— District Court (A finding by the District Court, quoted in a footnote, explaining the scope of the charged scheme.)
DOJ-OGR-00021900.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,694 characters)

Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page23 of 26
“materially different” from the allegations in the Indictment.48 The
evidence indicated that Maxwell transported Jane to New York for
sexual abuse and conspired to do the same. Maxwell knew that the
evidence also included conduct in New Mexico.49 Furthermore,
Maxwell cannot demonstrate “substantial prejudice.” Maxwell
received—over three weeks before trial—notes of Jane’s interview
recording the abuse she suffered in New Mexico. This is enough to
conclude that Maxwell was not “unfairly and substantially”
prejudiced.50
5. Maxwell’s Sentence Was Procedurally Reasonable
Lastly, Maxwell argues that her sentence was procedurally
unreasonable because the District Court erred in applying a leadership
sentencing enhancement under the Sentencing Guidelines and
inadequately explained its above-Guidelines sentence.51 We disagree.
48 Dove, 884 F.3d at 149.
49 As the District Court found, “[t]he Indictment charged a scheme to sexually abuse
underage girls in New York. In service of this scheme, the Indictment alleged that Epstein
and the Defendant groomed the victims for abuse at various properties and in various
states, including Epstein’s ranch in New Mexico.” A-393.
50 See United States v. Lebedev, 932 F.3d 40, 54 (2d Cir. 2019) (concluding that a defendant was
not “unfairly and substantially” prejudiced because “[t]he government disclosed the
evidence and exhibits . . . four weeks prior to trial”).
51 At sentencing, the District Court calculated a Guidelines range of 188 to 235 months’
imprisonment and sentenced Maxwell to a slightly above-Guidelines term of 240 months’
imprisonment.
23
DOJ-OGR-00021900

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