DOJ-OGR-00008930.jpg
712 KB
Extraction Summary
2
People
1
Organizations
3
Locations
2
Events
1
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
712 KB
Summary
This legal document is an Omnibus Memorandum filed on February 11, 2022, by Ghislaine Maxwell in support of her post-trial motions. The defense argues that her convictions on the Mann Act counts should be vacated due to a constructive amendment from the original indictment, asserting the government failed to properly prove a violation of New York law as required. The motion also seeks alternative relief, including a new trial, judgment on only one conspiracy count, or a complete dismissal of the indictment.
People (2)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
The document is an Omnibus Memorandum in Support of her Post-Trial Motions, submitted by Ghislaine Maxwell. She is re...
|
| Epstein |
Mentioned in the context of his residences in New Mexico and Florida where sexual activity occurred.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| The Court | government agency |
The entity to which Ghislaine Maxwell is submitting her Post-Trial Motions.
|
Timeline (2 events)
2022-02-11
Ghislaine Maxwell submitted an Omnibus Memorandum in Support of her Post-Trial Motions.
Ghislaine Maxwell's trial, which resulted in convictions that are now being challenged in this motion.
Ghislaine Maxwell
the government
Locations (3)
| Location | Context |
|---|---|
|
The location where the government argued Ms. Maxwell needed to have enticed underage girls to travel to, in violation...
|
|
|
Location of one of Epstein's residences where sexual activity occurred, which the government acknowledged was not suf...
|
|
|
Location of one of Epstein's residences where sexual activity occurred, which the government acknowledged was not suf...
|
Relationships (1)
The document mentions "Epstein's residences in New Mexico and Florida" in the context of sexual activity related to the charges against Ms. Maxwell, indicating a close association.
Full Extracted Text
Complete text extracted from the document (2,033 characters)
Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 6 of 37
Ghislaine Maxwell respectfully submits this Omnibus Memorandum in Support of her Post-Trial Motions. For the reasons set forth below, Ms. Maxwell moves the Court, in the alternative, to:
1. Vacate her convictions as to the Mann Act counts (Counts One through Four) and grant a new trial under Rule 33 because the convictions were based on a constructive amendment/variance from the allegations in the S2 Indictment (the “Indictment”).
2. Enter judgment on only one of the three conspiracy counts because they are multiplicitous.
3. Vacate her convictions as to all counts and dismiss the Indictment due to pre-indictment delay.
4. Enter a judgment of acquittal as to all counts under Rule 29 because the government failed to prove each element of the crimes charged beyond a reasonable doubt.
ARGUMENT
I. The Court Must Vacate Ms. Maxwell’s Convictions on the Mann Act Counts Due to a Constructive Amendment/Variance from the Crimes Charged in the Indictment.
Throughout this case, the government has consistently maintained that to convict Ms. Maxwell on the Mann Act Counts (Counts One through Four), it was necessary to prove that Ms. Maxwell enticed or caused underaged girls to travel to New York, or conspired to do the same, with the intent that they would engage in illegal sexual activity that violated New York law. The government further acknowledged that evidence of sexual activity that occurred in locations outside of New York, like Epstein’s residences in New Mexico and Florida, was not, by itself, sufficient to convict Ms. Maxwell on the Mann Act charges.
Nevertheless, the government repeatedly resisted numerous efforts by the defense to clarify these points for the jury, both in limiting instructions or in the jury charge itself. The government stressed over and over that the jury could not possibly be confused that the Mann Act counts had to involve a violation of New York law because the jury instructions charged
DOJ-OGR-00008930
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document