DOJ-OGR-00020994.jpg
666 KB
Extraction Summary
6
People
2
Organizations
0
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal filing / court order (appellate appendix)
File Size:
666 KB
Summary
This document is a page from a legal filing reviewing the trial of Ghislaine Maxwell (Case 1:20-cr-00330-AJN). It details the Government's argument that Maxwell utilized a specific 'playbook' to groom four specific victims (Jane, Annie, Carolyn, and Kate) for sexual abuse by Jeffrey Epstein. The text describes a 'pyramid scheme of abuse' beginning in 2001 involving payments for 'massage' appointments.
People (6)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Described as running a 'playbook' to groom victims; conspired with Epstein.
|
| Jeffrey Epstein | Co-conspirator |
Conspired with Maxwell to sexually abuse minors; received underage girls groomed by Maxwell.
|
| Jane | Witness/Victim |
Testified at trial; victim of the 'playbook'.
|
| Annie | Witness/Victim |
Testified at trial; groomed by Maxwell as part of agreement with Epstein.
|
| Carolyn | Witness/Victim |
The only witness who testified regarding Count Five; groomed by Maxwell.
|
| Kate | Witness/Victim |
Testified at trial; victim of the 'playbook'.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
Argued the case against Maxwell, describing her patterns and conspiracy.
|
|
| DOJ |
Indicated by Bates stamp DOJ-OGR-00020994.
|
Timeline (2 events)
2001
Start of the evolution of conduct into a 'pyramid scheme of abuse'.
Unknown
Relationships (2)
continuously conspired to sexually abuse minor victims; broader agreement to provide him with underage girls.
Maxwell groomed them; ran the same playbook on them.
Key Quotes (5)
"She ran the same playbook again and again and again. She manipulated her victims and she groomed them for sexual abuse."Source
DOJ-OGR-00020994.jpg
Quote #1
"The patterns you saw throughout this trial, the playbook that Maxwell ran for years, is just one of the many ways that you know that Maxwell is guilty."Source
DOJ-OGR-00020994.jpg
Quote #2
"Maxwell groomed both Annie and Carolyn as part of a broader agreement with Epstein to provide him with underage girls for abuse."Source
DOJ-OGR-00020994.jpg
Quote #3
"pyramid scheme of abuse"Source
DOJ-OGR-00020994.jpg
Quote #4
"paying them for so-called 'massage' appointments"Source
DOJ-OGR-00020994.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,247 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page168 of 221
A-368
A-368
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 11 of 45
minors for sexual abuse. Trial Tr. at 714–19. Applying that expert testimony to the witnesses’
testimony, the Government argued that the Defendant’s conduct as to each victim followed a
uniform “playbook.” E.g., id. at 2184 (“She ran the same playbook again and again and again.
She manipulated her victims and she groomed them for sexual abuse.”), 2853 (“The patterns you
saw throughout this trial, the playbook that Maxwell ran for years, is just one of the many ways
that you know that Maxwell is guilty.”). And the Government emphasized the many similarities
in the Defendant’s conduct as recounted by all four witnesses. Id. at 2848 (“The similarities
between what happened to Jane and Annie and Carolyn and Kate are incredibly powerful
evidence of the defendant’s guilt. So I want to talk to you about the playbook that Maxwell ran
again and again and again.”), 2901 (“Four women have testified at this trial about Maxwell.
They all describe the same woman, the same playbook.”). Carolyn was the only witness who
testified regarding Count Five. The Government argued that her testimony “was corroborated by
what Annie and Kate and Jane told [the jury] about Maxwell and how she operated for years.”
Id. at 2880; see also id. at 2895–96 (“Maxwell groomed both Annie and Carolyn as part of a
broader agreement with Epstein to provide him with underage girls for abuse.”). The
Government, in short, argued that the Defendant engaged in substantially the same operations for
a decade as to all victims under both Counts Three and Five.
testimony, the Government argued that the Defendant’s conduct as to each victim followed a
uniform “playbook.” E.g., id. at 2184 (“She ran the same playbook again and again and again.
She manipulated her victims and she groomed them for sexual abuse.”), 2853 (“The patterns you
saw throughout this trial, the playbook that Maxwell ran for years, is just one of the many ways
that you know that Maxwell is guilty.”). And the Government emphasized the many similarities
in the Defendant’s conduct as recounted by all four witnesses. Id. at 2848 (“The similarities
between what happened to Jane and Annie and Carolyn and Kate are incredibly powerful
evidence of the defendant’s guilt. So I want to talk to you about the playbook that Maxwell ran
again and again and again.”), 2901 (“Four women have testified at this trial about Maxwell.
They all describe the same woman, the same playbook.”). Carolyn was the only witness who
testified regarding Count Five. The Government argued that her testimony “was corroborated by
what Annie and Kate and Jane told [the jury] about Maxwell and how she operated for years.”
Id. at 2880; see also id. at 2895–96 (“Maxwell groomed both Annie and Carolyn as part of a
broader agreement with Epstein to provide him with underage girls for abuse.”). The
Government, in short, argued that the Defendant engaged in substantially the same operations for
a decade as to all victims under both Counts Three and Five.
The Government responds that while the Defendant and Epstein continuously conspired
to sexually abuse minor victims, their conduct beginning in 2001 evolved from developing one-
on-one relationships with their victims to include a “pyramid scheme of abuse,” by which they
acquired underage girls by paying them for so-called “massage” appointments. Gov. Br. at 32
(quoting Trial Tr. at 40). To be sure, the Government in both its opening statement and its
closing arguments explained that the Defendant and Epstein’s abuse “evolved over the course of
to sexually abuse minor victims, their conduct beginning in 2001 evolved from developing one-
on-one relationships with their victims to include a “pyramid scheme of abuse,” by which they
acquired underage girls by paying them for so-called “massage” appointments. Gov. Br. at 32
(quoting Trial Tr. at 40). To be sure, the Government in both its opening statement and its
closing arguments explained that the Defendant and Epstein’s abuse “evolved over the course of
11
DOJ-OGR-00020994
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