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587 KB
Extraction Summary
3
People
2
Organizations
1
Locations
2
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal filing (government response/memorandum)
File Size:
587 KB
Summary
This document is page 190 of a legal filing (Document 204) in the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on April 16, 2021. The Government argues against striking allegations related to 'Minor Victim-3,' asserting that her testimony regarding grooming and sex acts in London is probative of the defendant's intent and the conspiracy with Jeffrey Epstein, even if potential statute of limitations issues exist for specific charges. The document emphasizes that the evidence establishes the relationship between the defendant and Epstein.
People (3)
| Name | Role | Context |
|---|---|---|
| Minor Victim-3 | Victim/Witness |
Expected to testify regarding interactions with the defendant; subject of grooming and sex acts.
|
| The Defendant | Accused (Ghislaine Maxwell) |
Referenced regarding intent to entice victim to travel for sexual acts; relationship with Epstein. (Case 1:20-cr-0033...
|
| Jeffrey Epstein | Co-conspirator |
Mentioned in context of agreements and relationship with the defendant.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Government |
Arguing for the admissibility of evidence.
|
|
| The Court |
Will evaluate the evidence at trial.
|
Timeline (2 events)
Unspecified (Pre-2021)
Locations (1)
| Location | Context |
|---|---|
|
Location where grooming and sex acts involving Minor Victim-3 took place (mentioned in Footnote 58).
|
Relationships (2)
Document cites 'agreements between and the relationship of the defendant and Epstein.'
Defendant had 'initial interactions' to entice victim to travel for sexual acts.
Key Quotes (2)
"Government further expects Minor Victim-3 will testify that [REDACTED], which is probative of the defendant’s intent, in her initial interactions with Minor Victim-3, to entice Minor Victim-3 to travel and be transported for the purpose of engaging in sexual acts."Source
DOJ-OGR-00003124.jpg
Quote #1
"Regardless, the subsequent invitation demonstrates that the grooming and sex acts in London were part of conspiracies to entice and transport minors."Source
DOJ-OGR-00003124.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,130 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 190 of 239
Government further expects Minor Victim-3 will testify that [REDACTED], which is probative of the
defendant’s intent, in her initial interactions with Minor Victim-3, to entice Minor Victim-3 to
travel and be transported for the purpose of engaging in sexual acts. 58 Thus, even if Minor Victim-
3 did not travel as a minor, the events involving Minor Victim-3 outlined in the Indictment
constitute direct and admissible evidence of the agreements between and the relationship of the
defendant and Epstein. Because evidence regarding Minor Vitim-3 is therefore relevant and
admissible at trial, there is no basis to strike these allegations from the Indictment. See Scarpa,
913 F.2d at 1013. Given the relevance of these allegations, the defendant has not satisfied the
“exacting” standard required to justify striking portions of an Indictment. Murgio, 209 F. Supp.
3d at 724 (quoting Smith, 985 F. Supp. 2d at 610). Accordingly, the motion should be denied, or,
at the very least, deferred until “presentation of the Government’s evidence at trial” after which
the Court will have a full understanding of how Minor Victim-3’s experiences fit into the charged
conspiracies. Mostafa, 965 F. Supp. 2d at 467.
defendant’s intent, in her initial interactions with Minor Victim-3, to entice Minor Victim-3 to
travel and be transported for the purpose of engaging in sexual acts. 58 Thus, even if Minor Victim-
3 did not travel as a minor, the events involving Minor Victim-3 outlined in the Indictment
constitute direct and admissible evidence of the agreements between and the relationship of the
defendant and Epstein. Because evidence regarding Minor Vitim-3 is therefore relevant and
admissible at trial, there is no basis to strike these allegations from the Indictment. See Scarpa,
913 F.2d at 1013. Given the relevance of these allegations, the defendant has not satisfied the
“exacting” standard required to justify striking portions of an Indictment. Murgio, 209 F. Supp.
3d at 724 (quoting Smith, 985 F. Supp. 2d at 610). Accordingly, the motion should be denied, or,
at the very least, deferred until “presentation of the Government’s evidence at trial” after which
the Court will have a full understanding of how Minor Victim-3’s experiences fit into the charged
conspiracies. Mostafa, 965 F. Supp. 2d at 467.
The fact that the Government would be precluded, by virtue of the statute of limitations,
from bringing a charge based exclusively on the experience of Minor Victim-3 is immaterial. It is
well-established that a prosecution for a conspiracy is timely so long as the conspiracy exists and
at least one timely overt act is committed in furtherance of the conspiracy within the applicable
statute of limitations. See United States v. Salmonese, 352 F.3d 608, 614 (2d Cir. 2003) (citing
Grunewald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d
170, 174-75 (2d Cir. 2007); United States v. Mason, 479 F. App’x 397, 398 (2d Cir. 2012).
from bringing a charge based exclusively on the experience of Minor Victim-3 is immaterial. It is
well-established that a prosecution for a conspiracy is timely so long as the conspiracy exists and
at least one timely overt act is committed in furtherance of the conspiracy within the applicable
statute of limitations. See United States v. Salmonese, 352 F.3d 608, 614 (2d Cir. 2003) (citing
Grunewald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d
170, 174-75 (2d Cir. 2007); United States v. Mason, 479 F. App’x 397, 398 (2d Cir. 2012).
58
[REDACTED] Regardless, the subsequent invitation demonstrates that the grooming
and sex acts in London were part of conspiracies to entice and transport minors.
[REDACTED] Regardless, the subsequent invitation demonstrates that the grooming
and sex acts in London were part of conspiracies to entice and transport minors.
163
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