DOJ-OGR-00009578.jpg
649 KB
Extraction Summary
3
People
1
Organizations
5
Locations
4
Events
2
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
649 KB
Summary
This legal document, part of a court filing, argues that a jury note submitted during Ms. Maxwell's trial was ambiguous. The defense claimed the note referred to a specific 1997 flight to New Mexico, but this document contends the jury could have been referencing other flights or asking a different question entirely. The document concludes that the defendant's interpretation is 'mere conjecture' and supports the court's decision to reject the defense's arguments on this point.
People (3)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Mentioned as the defendant in the case, alleged to have intended for Jane to engage in sexual activity. She is listed...
|
| Jane | Witness / Alleged Victim |
Alleged victim of sexual activity intended by Ms. Maxwell. Listed as a passenger on a 1997 flight and provided testim...
|
| Epstein |
Mentioned as a passenger on a flight from Palm Beach to Santa Fe with the defendant and "1 female".
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| The Court | Government agency |
Mentioned as having correctly rejected the defendant's arguments during the trial.
|
Timeline (4 events)
A flight departing Santa Fe, for which the flight record did not include the defendant or Jane.
Departing Santa Fe
Trial during which the Court rejected arguments from the defendant.
Locations (5)
| Location | Context |
|---|---|
|
Location where sexual activity was allegedly intended to occur and the destination of a 1997 flight.
|
|
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Origin of a 1997 flight to New Mexico and a potential destination for a return trip.
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Destination of a flight from Palm Beach and origin of a subsequent flight.
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Origin of a flight to Santa Fe.
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|
|
Mentioned as a potential destination for a return flight that the defendant presumes the jury was focused on.
|
Relationships (2)
The document states they were both passengers on a 1997 flight from New York to New Mexico, and that Ms. Maxwell was accused of intending for Jane to engage in sexual activity.
They are listed as passengers on the same flight from Palm Beach to Santa Fe.
Key Quotes (1)
"if they found that Ms. Maxwell had intended Jane to engage in sexual activity in New Mexico."Source
— The document, describing a condition for a jury finding
(This phrase is quoted to set up the context of the defendant's arguments which the Court rejected during trial.)
DOJ-OGR-00009578.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (1,896 characters)
Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 16 of 51
if they found that Ms. Maxwell had intended Jane to engage in sexual activity in New Mexico.”
(Def. Mot. at 13). The Court was right to reject these arguments during trial.
(Def. Mot. at 13). The Court was right to reject these arguments during trial.
First, the meaning of the jury note is entirely ambiguous. It is at a minimum unclear (1)
which flights are referenced in the note, (2) where the sexual activity was intended to occur, and
(3) what question is posed by the note.
which flights are referenced in the note, (2) where the sexual activity was intended to occur, and
(3) what question is posed by the note.
The defendant argues that the note’s mention of a flight to New Mexico is a specific
reference to a 1997 flight from New York to New Mexico captured in the flight logs that lists both
the defendant and Jane as passengers. (See Def. Mot. at 14 (citing GX 662-R at 48)). The jury
may have considered that flight, or some other flight. (See, e.g., GX 662 at 51 (flight to Santa Fe
from Palm Beach with Epstein, the defendant, and “1 female”); Tr. 316 (testimony from Jane that
she sometimes traveled on commercial flights)). If it was that flight, the subsequent flight record
departing Santa Fe did not include the defendant or Jane (see GX 662 at 48), providing no
information about the flight that the defendant thinks was the focus of the jury’s attention. And to
the extent it was a “return” trip, the origin of the trip to New Mexico was New York, so the jury
could easily have inferred that the “return” trip was also to New York. That is, the defendant may
or may not be right about which flight the jury had in mind. And if the jury was asking about this
trip, the jury could well have been asking about a flight to New York—which, if the defendant
arranged, could have been highly significant and proper evidence of guilt. The defendant’s
presumption that the jury was focused on this particular trip and specifically on a return flight to
Florida with no relevance to the case is mere conjecture.
reference to a 1997 flight from New York to New Mexico captured in the flight logs that lists both
the defendant and Jane as passengers. (See Def. Mot. at 14 (citing GX 662-R at 48)). The jury
may have considered that flight, or some other flight. (See, e.g., GX 662 at 51 (flight to Santa Fe
from Palm Beach with Epstein, the defendant, and “1 female”); Tr. 316 (testimony from Jane that
she sometimes traveled on commercial flights)). If it was that flight, the subsequent flight record
departing Santa Fe did not include the defendant or Jane (see GX 662 at 48), providing no
information about the flight that the defendant thinks was the focus of the jury’s attention. And to
the extent it was a “return” trip, the origin of the trip to New Mexico was New York, so the jury
could easily have inferred that the “return” trip was also to New York. That is, the defendant may
or may not be right about which flight the jury had in mind. And if the jury was asking about this
trip, the jury could well have been asking about a flight to New York—which, if the defendant
arranged, could have been highly significant and proper evidence of guilt. The defendant’s
presumption that the jury was focused on this particular trip and specifically on a return flight to
Florida with no relevance to the case is mere conjecture.
15
DOJ-OGR-00009578
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