DOJ-OGR-00010566.jpg
744 KB
Extraction Summary
5
People
4
Organizations
1
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Court filing (sentencing memorandum/legal brief)
File Size:
744 KB
Summary
This document is page 31 of a legal filing (Document 670) from the case US v. Ghislaine Maxwell, dated June 22, 2022. The text argues for a sentencing enhancement based on 'undue influence' exerted over a victim named Carolyn. It details how the defendant (Maxwell) groomed Carolyn by exploiting her drug addiction with money, discussing her personal trauma, and directing Virginia (Giuffre) to teach Carolyn how to sexually gratify Jeffrey Epstein.
People (5)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant (Ghislaine Maxwell) |
Accused of exercising undue influence over victim Carolyn; directed Virginia to instruct Carolyn; arranged logistics ...
|
| Carolyn | Victim |
Subject of the 'undue influence' sentencing enhancement discussion; received money for drugs and gifts; instructed on...
|
| Jeffrey Epstein | Co-conspirator |
Owner of the Palm Beach mansion; recipient of sexual acts; sent gifts/lingerie to Carolyn with the defendant's help.
|
| Virginia | Victim/Witness |
Directed by the defendant to show Carolyn how to sexually gratify Epstein.
|
| Dr. Rocchio | Expert Witness |
Explained how compliments regarding the body can help build a relationship of trust and attachment (grooming).
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States District Court |
Implied by case header Case 1:20-cr-00330-PAE
|
|
| DOJ-OGR |
Department of Justice - Office of Government Relations (referenced in Bates stamp)
|
|
| 2d Cir. |
Cited in case law (United States v. Watkins)
|
|
| 7th Cir. |
Cited in case law (United States v. Patterson)
|
Locations (1)
| Location | Context |
|---|---|
|
Epstein's residence where appointments with Carolyn were set up.
|
Relationships (3)
Defendant complimented body, discussed trauma, gave money for drugs, arranged transport.
Defendant directed Virginia to teach Carolyn sexual acts.
Defendant helped Epstein send gifts; set up appointments at his mansion.
Key Quotes (4)
"the defendant directed Virginia to show Carolyn how to sexually gratify Epstein"Source
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Quote #1
"gave Carolyn what, to Carolyn, were large sums of money needed to fuel her drug addiction"Source
DOJ-OGR-00010566.jpg
Quote #2
"complimented her body... which—as Dr. Rocchio explained—can help to build a relationship of trust and attachment."Source
DOJ-OGR-00010566.jpg
Quote #3
"The defendant and Epstein encouraged Carolyn to engage in sex acts for money. That is undue influence."Source
DOJ-OGR-00010566.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,196 characters)
Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 31 of 55
be presumed because of the substantial difference in age between the participant and the minor.”
Id.
Id.
On the facts, the defendant does not resist application of this enhancement to any victim
other than Carolyn. As to Carolyn, the defendant ignores the presumption, instead arguing that
the record lacks evidence of additional acts of undue influence. (Def. Mem. 21-22). None is
required: the age difference alone provides a basis for the Court to apply the enhancement. See
United States v. Watkins, 667 F.3d 254, 264-65 (2d Cir. 2012) (applying the presumption and
noting that the defendant “failed to offer any evidence rebutting the presumption on this basis,”
even though the defendant argued that the “evidence demonstrated that [the defendant] failed to
compromise the voluntariness of [the victim]” (internal quotation marks and alteration omitted)).
And, in any event, the record shows that the defendant directed Virginia to show Carolyn how to
sexually gratify Epstein (Tr. 1521), called to set up appointments with Carolyn at Epstein’s lavish
Palm Beach mansion (Tr. 1527), sent cars or cabs to pick her up (Tr. 1532), gave Carolyn what, to
Carolyn, were large sums of money needed to fuel her drug addiction (Tr. 1528-31, 1541), and
helped Epstein send Carolyn gifts, including lingerie (Tr. 1541-42). The record also shows that
the defendant talked with Carolyn about her family problems, traumatic personal experiences, and
goals (Tr. 1534-35), and complimented her body (Tr. 1536), which—as Dr. Rocchio explained—
can help to build a relationship of trust and attachment. Although the defendant suggests that
Carolyn’s behavior was entirely voluntary, this was no arms-length transaction. The defendant
and Epstein encouraged Carolyn to engage in sex acts for money. That is undue influence. See,
e.g., United States v. Patterson, 576 F.3d 431, 443 (7th Cir. 2009) (affirming application of an
undue influence guideline where the victim “had never worked in prostitution before the defendant
encouraged her to try it” and “was destitute and penniless”). In support of her claim that Carolyn’s
other than Carolyn. As to Carolyn, the defendant ignores the presumption, instead arguing that
the record lacks evidence of additional acts of undue influence. (Def. Mem. 21-22). None is
required: the age difference alone provides a basis for the Court to apply the enhancement. See
United States v. Watkins, 667 F.3d 254, 264-65 (2d Cir. 2012) (applying the presumption and
noting that the defendant “failed to offer any evidence rebutting the presumption on this basis,”
even though the defendant argued that the “evidence demonstrated that [the defendant] failed to
compromise the voluntariness of [the victim]” (internal quotation marks and alteration omitted)).
And, in any event, the record shows that the defendant directed Virginia to show Carolyn how to
sexually gratify Epstein (Tr. 1521), called to set up appointments with Carolyn at Epstein’s lavish
Palm Beach mansion (Tr. 1527), sent cars or cabs to pick her up (Tr. 1532), gave Carolyn what, to
Carolyn, were large sums of money needed to fuel her drug addiction (Tr. 1528-31, 1541), and
helped Epstein send Carolyn gifts, including lingerie (Tr. 1541-42). The record also shows that
the defendant talked with Carolyn about her family problems, traumatic personal experiences, and
goals (Tr. 1534-35), and complimented her body (Tr. 1536), which—as Dr. Rocchio explained—
can help to build a relationship of trust and attachment. Although the defendant suggests that
Carolyn’s behavior was entirely voluntary, this was no arms-length transaction. The defendant
and Epstein encouraged Carolyn to engage in sex acts for money. That is undue influence. See,
e.g., United States v. Patterson, 576 F.3d 431, 443 (7th Cir. 2009) (affirming application of an
undue influence guideline where the victim “had never worked in prostitution before the defendant
encouraged her to try it” and “was destitute and penniless”). In support of her claim that Carolyn’s
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DOJ-OGR-00010566
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