DOJ-OGR-00020996.jpg
648 KB
Extraction Summary
8
People
2
Organizations
6
Locations
4
Events
4
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
648 KB
Summary
This legal document details how the Defendant and Epstein used financial gifts and payments as a grooming tactic to gain victims' trust and facilitate sexual abuse. It cites testimony from a victim named 'Jane' about receiving money and payments for lessons, and mentions promises made to another victim, 'Annie'. The document also discusses the geographic scope of the conspiracy, noting that sexual conduct occurred not only in New York and Florida but also in New Mexico and London, involving other victims like Carolyn and Virginia Roberts.
People (8)
| Name | Role | Context |
|---|---|---|
| Epstein |
Mentioned as an individual who, along with the Defendant, acquired victims' trust through financial gifts and payment...
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| Jane | Witness/Victim |
A witness who testified she was given money on almost every visit by Epstein, who also paid for her voice lessons, cl...
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| Annie | Victim |
Mentioned as a girl who was promised a trip to Thailand by the Defendant/Epstein as part of a grooming playbook.
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| Carolyn | Victim |
Mentioned as someone who, along with Virginia Roberts, was paid to give Epstein sexualized massages at his residence ...
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| Virginia Roberts | Victim |
Mentioned as someone who, along with Carolyn, was paid to give Epstein sexualized massages at his residence in Florida.
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| Haji | Litigant |
Mentioned in the case citation 'Haji v. Miller'.
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| Miller | Litigant |
Mentioned in the case citation 'Haji v. Miller'.
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| Defendant | Defendant |
An unnamed individual who, along with Epstein, acquired victims' trust and engaged in sexual abuse and conduct. The d...
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Mentioned as having emphasized that financial gifts were a step in the Defendant's grooming playbook.
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| The Court | government agency |
Mentioned as having admitted testimony concerning sexual conduct in various locations.
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Timeline (4 events)
Minors were transported to New York to engage in criminal sexual activity.
New York
Locations (6)
| Location | Context |
|---|---|
|
Mentioned as the destination for a trip promised to Annie.
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A location where minors were transported for criminal sexual activity, and the focus of Count Three.
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Location of Epstein's residence where Carolyn and Virginia Roberts were paid for massages, and the focus of Count Five.
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Mentioned as a location of sexual conduct by the Defendant or Epstein.
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Mentioned as a location of sexual conduct by the Defendant or Epstein.
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Eastern District of New York, mentioned in a case citation.
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Relationships (4)
The document describes them acting together to acquire victims' trust, extend sexual abuse, and having a shared 'conspiratorial objective'.
Epstein gave Jane money, gifts, and paid for her lessons and tuition as a means of 'inducement, enticement, and coercion' to facilitate sexual abuse.
Carolyn was paid to give Epstein 'sexualized massages' at his residence in Florida.
Virginia Roberts was paid to give Epstein 'sexualized massages' at his residence in Florida.
Key Quotes (5)
"[a]lmost every visit"Source
— Jane
(Describing how often she was given money.)
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Quote #1
"Then came the next step in the playbook: Making these girls feel special, giving them gifts, making friends, giving them money, promising to help with their futures, promises like sending Annie on a trip to Thailand or helping to pay for Jane’s voice lessons and tuition."Source
— Government
(Describing the Defendant's playbook of grooming.)
DOJ-OGR-00020996.jpg
Quote #2
"[Jane] told you that Epstein gave her money and gifts and paid for school. That money wasn’t free . . . . That is inducement, that is enticement, that is coercion."Source
— Government
(Characterizing the financial support Epstein gave to Jane.)
DOJ-OGR-00020996.jpg
Quote #3
"a wholly new agreement"Source
— Haji v. Miller case
(A legal term used to argue against the idea that the Defendant and Epstein's approach shifted dramatically in 2001.)
DOJ-OGR-00020996.jpg
Quote #4
"conspiratorial objective"Source
— Haji v. Miller case
(A legal term used in relation to the 'wholly new agreement'.)
DOJ-OGR-00020996.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,190 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page170 of 221
A-370
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 13 of 45
A-370
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 13 of 45
Further, in both counts, the witnesses testified that they received financial gifts and payments as a means by which the Defendant and Epstein acquired their victims’ trust and extended the period of sexual abuse. E.g., id. at 302 (Jane testified that she was given money “[a]lmost every visit” and that Epstein paid for things like voice lessons and clothes). The Government emphasized such financial gifts as one step in the Defendant’s playbook of grooming. E.g., id. at 2851 (“Then came the next step in the playbook: Making these girls feel special, giving them gifts, making friends, giving them money, promising to help with their futures, promises like sending Annie on a trip to Thailand or helping to pay for Jane’s voice lessons and tuition.”), 2890 (“[Jane] told you that Epstein gave her money and gifts and paid for school. That money wasn’t free . . . . That is inducement, that is enticement, that is coercion.”).
The financial quid pro quo may have become more explicit beginning in 2001, but that shift in approach is not nearly so dramatic as to suggest that the Defendant and Epstein at that time entered “a wholly new agreement” with a new “conspiratorial objective.” Haji v. Miller, 584 F. Supp. 2d 498, 519 (E.D.N.Y. 2008). The similarity-of-operations factor therefore favors the Defendant.
Overlap of geographic scope. There is some, albeit incomplete, geographic overlap between the two counts. Count Three focused on travel to New York because the ultimate objective of the conspiracy was to transport minors to New York to engage in criminal sexual activity in violation of New York law. Count Five, by contrast, focused on Epstein’s residence in Florida, where Carolyn and Virginia Roberts were paid to give Epstein sexualized massages. Nevertheless, some geographic overlap between the two counts remained. All four witnesses testified about sexual conduct by the Defendant or Epstein in locations other than New York, whether Florida, New Mexico, or London. The Court admitted such testimony concerning
The financial quid pro quo may have become more explicit beginning in 2001, but that shift in approach is not nearly so dramatic as to suggest that the Defendant and Epstein at that time entered “a wholly new agreement” with a new “conspiratorial objective.” Haji v. Miller, 584 F. Supp. 2d 498, 519 (E.D.N.Y. 2008). The similarity-of-operations factor therefore favors the Defendant.
Overlap of geographic scope. There is some, albeit incomplete, geographic overlap between the two counts. Count Three focused on travel to New York because the ultimate objective of the conspiracy was to transport minors to New York to engage in criminal sexual activity in violation of New York law. Count Five, by contrast, focused on Epstein’s residence in Florida, where Carolyn and Virginia Roberts were paid to give Epstein sexualized massages. Nevertheless, some geographic overlap between the two counts remained. All four witnesses testified about sexual conduct by the Defendant or Epstein in locations other than New York, whether Florida, New Mexico, or London. The Court admitted such testimony concerning
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DOJ-OGR-00020996
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