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692 KB
Extraction Summary
3
People
3
Organizations
2
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Court filing (government memorandum of law)
File Size:
692 KB
Summary
This document is page 48 of a court filing (Document 621) from February 25, 2022, in the case against Ghislaine Maxwell. The Government argues that the Court should deny Maxwell's Rule 29 motion for acquittal, specifically addressing Count One (conspiracy). The text references testimony from a victim named 'Jane' who stated she was abused by both Epstein and Maxwell in New York and was groomed through methods including 'field trips.'
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the motion for acquittal; accused of conspiring with Epstein to groom victims.
|
| Jeffrey Epstein | Co-conspirator |
Deceased financier; conspired with defendant to groom and abuse victims.
|
| Jane | Victim/Witness |
Testified regarding abuse by Epstein and Maxwell in New York; was taken on 'field trips' by Maxwell.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court |
Addressed in the filing (SDNY).
|
|
| Government |
Opposing the defendant's motion.
|
|
| DOJ |
Indicated in Bates stamp (DOJ-OGR).
|
Timeline (3 events)
Prior to 2022
Jane testified she was abused by Epstein and the defendant
New York
Locations (2)
| Location | Context |
|---|---|
|
Location of Epstein's home where abuse occurred; destination of travel mentioned in enticement counts.
|
|
|
Locations where victims were enticed to travel.
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Relationships (2)
defendant conspired with Epstein to groom minor victims
Jane testified that she was abused by Epstein and the defendant... making Jane feel special, in part by taking her on 'field trips'
Key Quotes (4)
"the jury could have readily concluded that the defendant conspired with Epstein to groom minor victims and entice them to travel to Epstein’s various properties, including his home in New York, to be sexually abused."Source
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Quote #1
"Jane testified that she was abused by Epstein and the defendant in New York. (Tr. 320)."Source
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Quote #2
"making Jane feel special, in part by taking her on 'field trips'"Source
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Quote #3
"There is not testimony whatsoever that Ghislaine Maxwell encouraged [Jane] to travel."Source
DOJ-OGR-00009610.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,031 characters)
Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 48 of 51
Because the defendant cannot meet her “heavy burden” of establishing either element of
unconstitutional delay, Cornielle, 171 F.3d at 752, let alone both, her motion to vacate her
conviction or dismiss the Indictment for pre-indictment delay is meritless and should be denied.
unconstitutional delay, Cornielle, 171 F.3d at 752, let alone both, her motion to vacate her
conviction or dismiss the Indictment for pre-indictment delay is meritless and should be denied.
IV. The Court Should Deny the Defendant’s Motion for Judgment of Acquittal Under
Rule 29
Rule 29
In a brief paragraph at the end of her motion, the defendant “reasserts th[e] same motion”
under Rule 29 she made following the close of the Government’s case and the close of her case
and “incorporates the arguments previously made to the Court.” (Def. Mot. at 30). The Court
should reject those arguments as it has before.
under Rule 29 she made following the close of the Government’s case and the close of her case
and “incorporates the arguments previously made to the Court.” (Def. Mot. at 30). The Court
should reject those arguments as it has before.
The defendant has only offered a specific challenge to the sufficiency of the evidence as to
Counts One and Two, the enticement counts. Specifically, the defendant argued that the record
lacked sufficient evidence that the defendant “or anyone else who allegedly participated in this
conspiracy persuaded, induced, or enticed Jane to travel to New York to engage in illegal sexual
activity.” (Tr. 2266-67; see Tr. 2269-70 (“There is not testimony whatsoever that Ghislaine
Maxwell encouraged [Jane] to travel.”)). Of course, the jury acquitted the defendant on Count
Two, the substantive enticement count. As to Count One, the jury could have readily concluded
that the defendant conspired with Epstein to groom minor victims and entice them to travel to
Epstein’s various properties, including his home in New York, to be sexually abused. For instance,
Jane testified that she was abused by Epstein and the defendant in New York. (Tr. 320). And the
record is replete with testimony regarding the manner in which the defendant worked with Epstein
to groom minor victims and entice them to travel to Epstein’s properties. (See, e.g., Tr. 300 (Jane
seeing the defendant topless), 348 (making Jane feel special, in part by taking her on “field trips”),
Counts One and Two, the enticement counts. Specifically, the defendant argued that the record
lacked sufficient evidence that the defendant “or anyone else who allegedly participated in this
conspiracy persuaded, induced, or enticed Jane to travel to New York to engage in illegal sexual
activity.” (Tr. 2266-67; see Tr. 2269-70 (“There is not testimony whatsoever that Ghislaine
Maxwell encouraged [Jane] to travel.”)). Of course, the jury acquitted the defendant on Count
Two, the substantive enticement count. As to Count One, the jury could have readily concluded
that the defendant conspired with Epstein to groom minor victims and entice them to travel to
Epstein’s various properties, including his home in New York, to be sexually abused. For instance,
Jane testified that she was abused by Epstein and the defendant in New York. (Tr. 320). And the
record is replete with testimony regarding the manner in which the defendant worked with Epstein
to groom minor victims and entice them to travel to Epstein’s properties. (See, e.g., Tr. 300 (Jane
seeing the defendant topless), 348 (making Jane feel special, in part by taking her on “field trips”),
47
DOJ-OGR-00009610
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