DOJ-OGR-00008670.jpg
727 KB
Extraction Summary
5
People
2
Organizations
4
Locations
4
Events
3
Relationships
4
Quotes
Document Information
Type:
Court filing - jury instructions (case 1:20-cr-00330-pae)
File Size:
727 KB
Summary
This document is a page from jury instructions (Instruction No. 36) filed on December 18, 2021, in the case against Ghislaine Maxwell. It details the 'Third Element' of conspiracy, requiring an 'overt act,' and lists specific alleged acts including group sexual encounters involving Maxwell, Epstein, and a minor named Jane (1994-1997), an unsolicited massage given by Maxwell to Annie in New Mexico (1996), and travel invitations to a minor named Carolyn (2001-2002).
People (5)
| Name | Role | Context |
|---|---|---|
| Maxwell | Defendant/Conspirator |
Accused of participating in group sexual encounters and enticing minors.
|
| Epstein | Conspirator |
Accused of participating in group sexual encounters and traveling with minors.
|
| Jane | Victim (Minor) |
Under age of 17 during 1994-1997; subject to sexual encounters and enticed travel.
|
| Annie | Victim |
Received unsolicited massage from Maxwell in New Mexico while topless in 1996.
|
| Carolyn | Victim (Minor) |
Under age of 17 during 2001-2002; invited to travel with Epstein.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
Must prove elements beyond a reasonable doubt.
|
|
| DOJ |
Indicated by footer stamp DOJ-OGR.
|
Timeline (4 events)
Locations (4)
| Location | Context |
|---|---|
|
Location of sexual encounters and destination of travel.
|
|
|
Location of sexual encounters and origin of travel.
|
|
|
Specific location of sexual abuse.
|
|
|
Location where Maxwell provided a massage to Annie.
|
Key Quotes (4)
"Maxwell participated in multiple group sexual encounters with Epstein and Jane in New York and Florida"Source
DOJ-OGR-00008670.jpg
Quote #1
"Jane was enticed to travel from Florida to New York for purposes of sexually abusing her at the New York Residence"Source
DOJ-OGR-00008670.jpg
Quote #2
"Maxwell provided Annie with an unsolicited massage in New Mexico, during which Annie was topless"Source
DOJ-OGR-00008670.jpg
Quote #3
"Maxwell and Epstein invited Carolyn to travel from Florida to a place outside of Florida with Epstein"Source
DOJ-OGR-00008670.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,139 characters)
Case 1:20-cr-00330-PAE Document 563 Filed 12/18/21 Page 132 of 167
1 Instruction No. 36: Counts One, Three, and Five: Conspiracy to Violate Federal Law –
2 Third Element
3 The third element that the Government must prove beyond a reasonable doubt to
4 establish the offense of conspiracy is that at least one overt act was knowingly committed by at
5 least one of the conspirators.
6 The overt act element requires the Government to show something more than mere
7 agreement; some overt step or action must have been taken by at least one of the conspirators in
8 furtherance of that conspiracy. In other words, the Government must show that the agreement
9 went beyond the mere talking stage. It must show that at least one of the conspirators actually
10 did something in furtherance of the conspiracy.
11 With respect to the overt acts for Count One, the Indictment alleges as follows:
12 (1) Between in or about 1994 and in or about 1997, when Jane was under the age of 17, Maxwell
13 participated in multiple group sexual encounters with Epstein and Jane in New York and Florida;
14 (2) In or about 1996, when Jane was under the age of 17, Jane was enticed to travel from Florida
15 to New York for purposes of sexually abusing her at the New York Residence, in violation of
16 New York Penal Law, Section 130.55; (3) In or about 1996, Maxwell provided Annie with an
17 unsolicited massage in New Mexico, during which Annie was topless; (4) Between in or about
18 2001 and in or about 2002, when Carolyn was under the age of 17, Maxwell and Epstein invited
19 Carolyn to travel from Florida to a place outside of Florida with Epstein.
20 With respect to the overt acts for Count Three, the Indictment alleges as follows: (1)
21 Between in or about 1994 and in or about 1997, when Jane was under the age of 17, Maxwell
22 participated in multiple group sexual encounters with Epstein and Jane in New York and Florida;
23 (2) In or about 1996, when Jane was under the age of 17, Jane was enticed to travel from Florida
24 to New York for purposes of sexually abusing her at the New York Residence, in violation of
2 Third Element
3 The third element that the Government must prove beyond a reasonable doubt to
4 establish the offense of conspiracy is that at least one overt act was knowingly committed by at
5 least one of the conspirators.
6 The overt act element requires the Government to show something more than mere
7 agreement; some overt step or action must have been taken by at least one of the conspirators in
8 furtherance of that conspiracy. In other words, the Government must show that the agreement
9 went beyond the mere talking stage. It must show that at least one of the conspirators actually
10 did something in furtherance of the conspiracy.
11 With respect to the overt acts for Count One, the Indictment alleges as follows:
12 (1) Between in or about 1994 and in or about 1997, when Jane was under the age of 17, Maxwell
13 participated in multiple group sexual encounters with Epstein and Jane in New York and Florida;
14 (2) In or about 1996, when Jane was under the age of 17, Jane was enticed to travel from Florida
15 to New York for purposes of sexually abusing her at the New York Residence, in violation of
16 New York Penal Law, Section 130.55; (3) In or about 1996, Maxwell provided Annie with an
17 unsolicited massage in New Mexico, during which Annie was topless; (4) Between in or about
18 2001 and in or about 2002, when Carolyn was under the age of 17, Maxwell and Epstein invited
19 Carolyn to travel from Florida to a place outside of Florida with Epstein.
20 With respect to the overt acts for Count Three, the Indictment alleges as follows: (1)
21 Between in or about 1994 and in or about 1997, when Jane was under the age of 17, Maxwell
22 participated in multiple group sexual encounters with Epstein and Jane in New York and Florida;
23 (2) In or about 1996, when Jane was under the age of 17, Jane was enticed to travel from Florida
24 to New York for purposes of sexually abusing her at the New York Residence, in violation of
49
DOJ-OGR-00008670
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