DOJ-OGR-00021733.jpg
692 KB
Extraction Summary
4
People
2
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal brief / court filing (appellate)
File Size:
692 KB
Summary
This page from a Department of Justice appellate brief argues against Ghislaine Maxwell's appeal regarding jury instructions. The document asserts that Judge Nathan correctly handled an ambiguous jury note concerning flight evidence and 'aiding and abetting' liability. It specifically references testimony by a victim named 'Jane' regarding flights on Epstein's private plane and commercial carriers to New York for the purpose of sexual activity.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Appellant |
Her legal arguments regarding jury instructions and flight evidence are being refuted.
|
| Judge Nathan | Trial Judge |
Her response to a jury note is defended as sound and within judicial discretion.
|
| Jane | Witness/Victim |
Testified about taking numerous flights on Epstein's plane and commercial carriers; victim of trafficking.
|
| Jeffrey Epstein | Associate |
Mentioned in relation to his private plane.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Department of Justice (DOJ) |
Indicated by the footer DOJ-OGR.
|
|
| 2nd Circuit Court of Appeals |
Implied by case citations (e.g., 2d Cir. 2012).
|
Locations (1)
| Location | Context |
|---|---|
|
Origin and destination of a specific flight discussed regarding jury focus and trafficking intent.
|
Relationships (2)
Text states: 'Maxwell intended Jane to engage in sexual activity.'
Jane testified about flights on 'Epstein's private plane'.
Key Quotes (4)
"Judge Nathan’s response to the jury note was sound and did not constructively amend the Indictment."Source
DOJ-OGR-00021733.jpg
Quote #1
"Maxwell intended Jane to engage in sexual activity."Source
DOJ-OGR-00021733.jpg
Quote #2
"taking numerous flights both on Epstein’s private plane and on commercial carriers."Source
DOJ-OGR-00021733.jpg
Quote #3
"whether sexual activity was a sufficiently ‘significant or motivating purpose’ for the travel."Source
DOJ-OGR-00021733.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,789 characters)
Case 22-1426, Document 79, 06/29/2023, 3536060, Page86 of 93
73
requesting instead a series of instructions that were
“unresponsive,” “redundant,” and “legally inaccurate.”
(A.388-89). See Rommy, 506 F.3d at 126 (court re-
sponding to jury note “is not required to reference spe-
cific arguments advanced or defenses raised by counsel
in urging particular outcomes”). Judge Nathan’s re-
sponse to the jury note was sound and did not con-
structively amend the Indictment.
“unresponsive,” “redundant,” and “legally inaccurate.”
(A.388-89). See Rommy, 506 F.3d at 126 (court re-
sponding to jury note “is not required to reference spe-
cific arguments advanced or defenses raised by counsel
in urging particular outcomes”). Judge Nathan’s re-
sponse to the jury note was sound and did not con-
structively amend the Indictment.
Maxwell’s contrary view rests on extensive specu-
lation about “which flights and evidence the jury was
referencing in the note.” (A.386). The trial included,
among other evidence, testimony by Jane about “tak-
ing numerous flights both on Epstein’s private plane
and on commercial carriers.” (A.386). Maxwell ignores
that evidence, focusing on a specific trip referenced in
the flight logs. (Br.78-79). Even if Maxwell correctly
identified the flight at issue, it still betrayed no jury
confusion. The origin of that trip was New York, and
the jury’s focus was on the “return flight”—which it
could have inferred was a flight to New York, where
Maxwell intended Jane to engage in sexual activity.
lation about “which flights and evidence the jury was
referencing in the note.” (A.386). The trial included,
among other evidence, testimony by Jane about “tak-
ing numerous flights both on Epstein’s private plane
and on commercial carriers.” (A.386). Maxwell ignores
that evidence, focusing on a specific trip referenced in
the flight logs. (Br.78-79). Even if Maxwell correctly
identified the flight at issue, it still betrayed no jury
confusion. The origin of that trip was New York, and
the jury’s focus was on the “return flight”—which it
could have inferred was a flight to New York, where
Maxwell intended Jane to engage in sexual activity.
Her view also rests on adopting one specific reading
of a note that, as Judge Nathan explained, was “decid-
edly ambiguous as to the precise legal question being
asked” (A.386). See Rommy, 506 F.3d at 126 (district
court “enjoys considerable discretion in construing the
scope of a jury inquiry”). Maxwell herself initially un-
derstood the note to be about “aiding and abetting” li-
ability, and whether sexual activity was a sufficiently
“‘significant or motivating purpose’ for the travel.”
(A.387); see United States v. Kim, 471 F. App’x 82, 84
(2d Cir. 2012) (affirming jury instructions that
of a note that, as Judge Nathan explained, was “decid-
edly ambiguous as to the precise legal question being
asked” (A.386). See Rommy, 506 F.3d at 126 (district
court “enjoys considerable discretion in construing the
scope of a jury inquiry”). Maxwell herself initially un-
derstood the note to be about “aiding and abetting” li-
ability, and whether sexual activity was a sufficiently
“‘significant or motivating purpose’ for the travel.”
(A.387); see United States v. Kim, 471 F. App’x 82, 84
(2d Cir. 2012) (affirming jury instructions that
DOJ-OGR-00021733
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