DOJ-OGR-00008926.jpg
652 KB
Extraction Summary
3
People
1
Organizations
1
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal filing (table of contents)
File Size:
652 KB
Summary
This document is the Table of Contents (page 'i') for a legal filing (Document 600) in the case against Ghislaine Maxwell, filed on February 11, 2022. The filing outlines arguments to vacate Maxwell's convictions on Mann Act counts due to variances from the indictment, consolidate conspiracy counts because they are multiplicitous, and dismiss the indictment due to pre-indictment delay. It references specific evidence types including flight records, passenger manifests, and financial documents.
People (3)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Subject of the motion to vacate convictions; argument claims she was prejudiced by variance in proof and indictment.
|
| The Court | Judiciary |
Addressed in the motion; requested to vacate convictions and enter judgment.
|
| The Jury | Fact Finder |
Mentioned regarding legal instructions and a jury note.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| DOJ |
Implied by the Bates stamp 'DOJ-OGR' (Department of Justice - Office of Government Relations).
|
Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in relation to the Mann Act counts and the scheme to entice girls to travel there.
|
Relationships (1)
Reference to 'Scheme to Entice or Cause Underaged Girls to Travel'
Key Quotes (4)
"The Court Must Vacate Ms. Maxwell’s Convictions on the Mann Act Counts Due to a Constructive Amendment/Variance from the Crimes Charged in the Indictment"Source
DOJ-OGR-00008926.jpg
Quote #1
"The 'Core of Criminality' of the Mann Act Counts Was a Scheme to Entice or Cause Underaged Girls to Travel to New York with an Intent to Violate New York Law"Source
DOJ-OGR-00008926.jpg
Quote #2
"The Court Should Enter Judgment on Only One of the Three Conspiracy Counts Because They Are Multiplicitous"Source
DOJ-OGR-00008926.jpg
Quote #3
"The Proof at Trial Established, at Most, a Single Conspiracy"Source
DOJ-OGR-00008926.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,743 characters)
Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 2 of 37
TABLE OF CONTENTS
Page
ARGUMENT.......... 1
ARGUMENT.......... 1
I. The Court Must Vacate Ms. Maxwell’s Convictions on the Mann Act Counts Due to a Constructive Amendment/Variance from the Crimes Charged in the Indictment....... 1
A. Background Facts.......... 3
1. Legal Instructions to the Jury.......... 3
2. The Jury Note.......... 6
B. Applicable Law.......... 7
C. The “Core of Criminality” of the Mann Act Counts Was a Scheme to Entice or Cause Underaged Girls to Travel to New York with an Intent to Violate New York Law.......... 9
D. There is a Substantial Likelihood that Ms. Maxwell Was Convicted on Three of the Mann Act Counts Based on Conduct Not Charged in the Indictment.......... 11
E. The Variance Between the Proof at Trial and the Allegations in the Indictment Substantially Prejudiced Ms. Maxwell.......... 16
II. The Court Should Enter Judgment on Only One of the Three Conspiracy Counts Because They Are Multiplicitous.......... 18
A. Applicable Law.......... 19
B. The Proof at Trial Established, at Most, a Single Conspiracy.......... 21
1. Overlap of Participants and Time.......... 22
2. Similarity of Operation, Common Objectives, and Geographic Scope.... 23
3. Common Overt Acts.......... 24
4. Degree of Interdependence Between the Conspiracies.......... 24
III. The Court Should Vacate Ms. Maxwell’s Conviction and Dismiss the S2 Indictment Due to Pre-Indictment Delay.......... 25
A. Flight Records – Passenger Manifests and Shoppers Travel Records.......... 26
B. Financial Documents – Bank Records and Credit Card Records.......... 27
i
DOJ-OGR-00008926
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