DOJ-OGR-00020992.jpg
652 KB
Extraction Summary
2
People
4
Organizations
0
Locations
2
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal brief / court filing (appeal or motion)
File Size:
652 KB
Summary
This document is a page from a legal filing (likely an appeal brief) arguing that certain counts against the Defendant are 'multiplicitous' (charging the same offense multiple times). It cites legal precedents regarding conspiracy charges and argues that because the participants (specifically the Defendant and Epstein) and the objectives (acquiring underage girls for Epstein to abuse) overlapped substantially, the counts should be considered the same conspiracy. It explicitly describes the Defendant's role as procuring girls for Epstein.
People (2)
| Name | Role | Context |
|---|---|---|
| Epstein | Primary Coconspirator |
Described as the Defendant's primary coconspirator in both conspiracies; the person for whom underage girls were acqu...
|
| The Defendant | Defendant |
Accused of playing the role of acquiring underage girls for Epstein; described as a 'partner in crime'. (Contextually...
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Government |
Argued the case against the Defendant; conceded points regarding multiplicitous counts.
|
|
| United States |
Referenced in case citations (United States v. Broce, etc.).
|
|
| 2d Cir. |
Second Circuit Court of Appeals, cited in case law.
|
|
| DOJ |
Department of Justice, indicated by the footer stamp 'DOJ-OGR'.
|
Timeline (2 events)
Over a decade
The duration of the alleged conspiracy where the defendant and Epstein were 'partners in crime'.
Unspecified
Various (Trial timeline)
Trial proceedings referenced via transcript pages (Trial Tr. at 34, 2842, 2885).
Court
Relationships (1)
Described as 'partners in crime' and 'primary coconspirator' in the document text.
Key Quotes (5)
"Epstein was the Defendant’s primary coconspirator in both conspiracies"Source
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Quote #1
"the Defendant played the same role of acquiring underage girls for Epstein to sexually abuse."Source
DOJ-OGR-00020992.jpg
Quote #2
"They were, the Government explained, “partners in crime” over the decade alleged in the Indictment."Source
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Quote #3
"“For a decade, the defendant played an essential role in this scheme.”"Source
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Quote #4
"“[a] single agreement to commit several crimes constitutes one conspiracy.”"Source
DOJ-OGR-00020992.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,226 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page166 of 221
A-366
A-366
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 9 of 45
*11 (concluding that conspiracies to defraud the United States and to commit mail and wire
fraud were the same conspiracy as earlier conspiracy to use or transfer false IDs). After all, “[a]
single agreement to commit several crimes constitutes one conspiracy.” United States v. Broce,
488 U.S. 563, 570–71 (1989). The Government implicitly conceded this point of law when it
agreed that Counts One and Three were multiplicitous. Count One charges a conspiracy to
entice minors to travel across state lines in violation of 18 U.S.C. § 2422 while Count Three
charges a conspiracy to transport minors across state lines in violation of 18 U.S.C. § 2423(a).
Despite distinct statutory predicates for these two § 371 conspiracies, the Government did not
contest that they were the same offense. Though Count Five is unquestionably less similar to
Count Three than is Count One, the difference in statutory predicates does not end the matter. It
is well established that a single conspiracy can contain multiple objectives, particularly if the
objectives share important similarities, as they do here. United States v. Salameh, 152 F.3d 88,
148 (2d Cir. 1998) (citing United States v. Aracri, 968 F.2d 1512, 1518 (2d Cir. 1992)).
fraud were the same conspiracy as earlier conspiracy to use or transfer false IDs). After all, “[a]
single agreement to commit several crimes constitutes one conspiracy.” United States v. Broce,
488 U.S. 563, 570–71 (1989). The Government implicitly conceded this point of law when it
agreed that Counts One and Three were multiplicitous. Count One charges a conspiracy to
entice minors to travel across state lines in violation of 18 U.S.C. § 2422 while Count Three
charges a conspiracy to transport minors across state lines in violation of 18 U.S.C. § 2423(a).
Despite distinct statutory predicates for these two § 371 conspiracies, the Government did not
contest that they were the same offense. Though Count Five is unquestionably less similar to
Count Three than is Count One, the difference in statutory predicates does not end the matter. It
is well established that a single conspiracy can contain multiple objectives, particularly if the
objectives share important similarities, as they do here. United States v. Salameh, 152 F.3d 88,
148 (2d Cir. 1998) (citing United States v. Aracri, 968 F.2d 1512, 1518 (2d Cir. 1992)).
Overlap of participants. The participants in the two conspiracies in Counts Three and
Five substantially overlap with one another. Of course, the defendant will always overlap
between two allegedly multiplicitous conspiracies, so their participation in both conspiracies has
negligible significance. Villa, 2014 WL 252013, at *5. More importantly here, Epstein was the
Defendant’s primary coconspirator in both conspiracies, and the Government argued that in both
conspiracies the Defendant played the same role of acquiring underage girls for Epstein to
sexually abuse. They were, the Government explained, “partners in crime” over the decade
alleged in the Indictment. E.g., Trial Tr. at 34, 2842, 2885; see also id. at 41 (“For a decade, the
defendant played an essential role in this scheme.”). This overlap in key participants, and in core
Five substantially overlap with one another. Of course, the defendant will always overlap
between two allegedly multiplicitous conspiracies, so their participation in both conspiracies has
negligible significance. Villa, 2014 WL 252013, at *5. More importantly here, Epstein was the
Defendant’s primary coconspirator in both conspiracies, and the Government argued that in both
conspiracies the Defendant played the same role of acquiring underage girls for Epstein to
sexually abuse. They were, the Government explained, “partners in crime” over the decade
alleged in the Indictment. E.g., Trial Tr. at 34, 2842, 2885; see also id. at 41 (“For a decade, the
defendant played an essential role in this scheme.”). This overlap in key participants, and in core
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DOJ-OGR-00020992
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