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705 KB
Extraction Summary
6
People
2
Organizations
1
Locations
3
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal court filing (case 1:20-cr-00330-pae)
File Size:
705 KB
Summary
This page of a court document discusses the legal arguments regarding the conspiracy charges against Ms. Maxwell and Epstein. It argues that despite violating different statutes, the actions constituted a single criminal agreement to groom and abuse minors, rather than separate independent conspiracies, and analyzes the interdependence between the counts.
People (6)
| Name | Role | Context |
|---|---|---|
| Epstein | ||
| Ms. Maxwell | ||
| Jane | ||
| Kate | ||
| Annie Farmer | ||
| Carolyn |
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Court | ||
| Government |
Timeline (3 events)
Mann Act conspiracies
Sex trafficking conspiracy
Trial by jury
Locations (1)
| Location | Context |
|---|---|
Relationships (2)
→
Co-conspirators in a single criminal agreement
→
→
Victim specifically related to the overt acts in Count Five
→
Key Quotes (3)
"The final step was for Epstein and Ms. Maxwell to normalize sexual situations and sexual touching so that it would eventually escalate to more serious sexualized massages."Source
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Quote #1
"the government’s theory as presented to the jury was that it was a single criminal agreement between Epstein and Ms. Maxwell, not separate independent conspiracies."Source
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Quote #2
"Count Five was simply a subset of the larger conspiracy charged in Counts One and Three"Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,088 characters)
Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 29 of 37
them feel special, giving them gifts or much-needed cash, or promising to help with their futures.
Tr. 2850:18-2851:17. The final step was for Epstein and Ms. Maxwell to normalize sexual
situations and sexual touching so that it would eventually escalate to more serious sexualized
massages. Tr. 2851:18-2852:24.
Tr. 2850:18-2851:17. The final step was for Epstein and Ms. Maxwell to normalize sexual
situations and sexual touching so that it would eventually escalate to more serious sexualized
massages. Tr. 2851:18-2852:24.
Moreover, this common method of operation to recruit and “groom” minors was all in
service of the same objective: to sexually abuse underage girls. Although this common scheme
violated three different statutes and the incidents of abuse took place in different locations, the
government’s theory as presented to the jury was that it was a single criminal agreement between
Epstein and Ms. Maxwell, not separate independent conspiracies.
service of the same objective: to sexually abuse underage girls. Although this common scheme
violated three different statutes and the incidents of abuse took place in different locations, the
government’s theory as presented to the jury was that it was a single criminal agreement between
Epstein and Ms. Maxwell, not separate independent conspiracies.
3. Common Overt Acts
The Mann Act conspiracies charged in Counts One and Three alleged identical overt acts,
which pertained to each of the four accusers. Ind. ¶¶ 13a-e and 19a-e. Because the sex
trafficking conspiracy charged in Count Five did not involve Jane, Kate, or Annie Farmer, that
count alleged separate overt acts related solely to Carolyn. Ind. ¶¶ 25a-d. As discussed above,
however, Count Five was simply a subset of the larger conspiracy charged in Counts One and
Three involving Carolyn and other accusers in Florida and did not represent a separate
conspiracy. See discussion supra.
which pertained to each of the four accusers. Ind. ¶¶ 13a-e and 19a-e. Because the sex
trafficking conspiracy charged in Count Five did not involve Jane, Kate, or Annie Farmer, that
count alleged separate overt acts related solely to Carolyn. Ind. ¶¶ 25a-d. As discussed above,
however, Count Five was simply a subset of the larger conspiracy charged in Counts One and
Three involving Carolyn and other accusers in Florida and did not represent a separate
conspiracy. See discussion supra.
4. Degree of Interdependence Between the Conspiracies
This factor requires the Court to consider the extent to which the success or failure of one
alleged conspiracy is independent of a corresponding success or failure by the other. Macchia,
35 F.3d at 671. The conspiracy alleged in Count Three was logically dependent on the success
of the conspiracy alleged in Count One. The object of both was to first entice and then transport
minors across state lines for the purpose of engaging in illegal sexual activity. If the conspiracy
to entice failed there would, logically, be no one to transport. Similarly, the object of the sex
alleged conspiracy is independent of a corresponding success or failure by the other. Macchia,
35 F.3d at 671. The conspiracy alleged in Count Three was logically dependent on the success
of the conspiracy alleged in Count One. The object of both was to first entice and then transport
minors across state lines for the purpose of engaging in illegal sexual activity. If the conspiracy
to entice failed there would, logically, be no one to transport. Similarly, the object of the sex
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