DOJ-OGR-00005834.jpg
775 KB
Extraction Summary
3
People
1
Organizations
1
Locations
3
Events
2
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
775 KB
Summary
This legal document, filed on October 29, 2021, is a prosecution argument asserting that evidence related to the defendant's involvement with "Minor Victim-3" is admissible in court. The prosecution argues these actions are direct evidence of the defendant's role in a conspiracy to provide minors to Jeffrey Epstein for sexual abuse. The document dismisses the relevance of United Kingdom law and clarifies that this evidence is crucial for demonstrating the defendant's knowledge and participation in the scheme, even if a conviction cannot be based solely on this victim's testimony due to the statute of limitations.
People (3)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein |
Mentioned as the individual for whom the defendant allegedly provided access to girls under 18 for the purpose of sex...
|
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| Minor Victim-3 | Victim |
An individual whose exploitation by the defendant is presented as direct evidence of the charged conspiracy.
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| The defendant | Defendant |
The subject of the legal filing, accused of conspiring to transport and entice minors for Jeffrey Epstein.
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Organizations (1)
| Name | Type | Context |
|---|---|---|
| Government | Government agency |
Referred to as the prosecuting party in the case, as cited in footnotes (Gov't Opp.).
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Timeline (3 events)
The trial where the jury will determine if the defendant took steps to provide Jeffrey Epstein with access to girls under 18.
The defendant is charged with conspiring to transport and entice minors for the purpose of sexual abuse by Jeffrey Epstein.
The defendant's alleged efforts to recruit and encourage Minor Victim-3 to engage in sex acts with Epstein in the context of massages.
Locations (1)
| Location | Context |
|---|---|
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Mentioned in the context of its laws and age of consent, which the document argues are irrelevant to the charges agai...
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Relationships (2)
The document alleges the defendant is charged with conspiring to provide Jeffrey Epstein with access to girls under 18 for sexual abuse.
The document states the defendant's acts involved the exploitation of Minor Victim-3, including efforts to recruit and encourage her to engage in sex acts with Epstein.
Full Extracted Text
Complete text extracted from the document (2,306 characters)
Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 51 of 84
Not so. The defendant’s argument entirely misunderstands the charges in the Indictment and the jury’s task at trial. The defendant is charged with conspiring to transport and entice minors for the purpose of sexual abuse. The question at trial will be whether the defendant took steps to provide Jeffrey Epstein with access to girls under the age of 18, knowing that Epstein intended to have sexual contact with those girls. The defendant’s acts involving Minor Victim-3 were part of that scheme and are highly relevant to demonstrating the existence of the conspiracy and the defendant’s role in the scheme. That is all that is required for evidence relating to the defendant’s exploitation of Minor Victim-3 to be direct evidence of the charged offenses. The defendant is not charged with an offense under United Kingdom law, and the age of consent in the United Kingdom is irrelevant. The defendant is also not charged with any substantive offenses with respect to Minor Victim-3, and thus it makes no difference whether the defendant could have, attempted to, or did successfully transport Minor Victim-3 in violation of those statutes.12
In any event, this evidence is all admissible under Rule 404(b).13 Testimony regarding the defendant’s efforts to recruit and encourage Minor Victim-3 to engage in sex acts with Epstein in the context of massages establishes that the defendant knew of Epstein’s attraction to minor girls
12 Indeed, there is no risk at trial that the jury will convict the defendant based on the testimony of Minor Victim-3 alone. As the Government has made clear, the jury may not convict the defendant of the conspiracy offense solely based on Minor Victim-3 due to the statute of limitations. (Gov’t Opp. at 157-58, 163, Dkt. No. 204). The jury should be appropriately instructed at the conclusion of the trial.
13 To the extent this evidence is properly admissible under Rule 404(b) rather than as direct evidence, the Government’s detailed memorandum in opposition to the defense pretrial motions, which described theories of 404(b) admissibility (Gov’t Opp. at 165-69, Dkt. No. 204), and this memorandum, filed five weeks before trial, is more than sufficient notice for the defense.
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DOJ-OGR-00005834
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