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Extraction Summary
4
People
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Organizations
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Locations
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Events
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Relationships
3
Quotes
Document Information
Type:
Legal filing (court document - case 1:20-cr-00330-pae)
File Size:
638 KB
Summary
This document is page 31 of a legal filing from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), dated February 25, 2022. It argues against a defense claim of 'multiplicity' regarding conspiracy counts, referencing trial testimony from a victim named Carolyn. The text highlights that Sarah Kellen, Epstein's personal assistant since the early 2000s, contacted Carolyn to schedule appointments for sexualized massages.
People (4)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant |
Subject of the legal motion regarding multiplicity of counts (Ghislaine Maxwell, implied by case number)
|
| Jeffrey Epstein | Co-conspirator |
Mentioned as involved in conspiracies with the defendant and employer of Sarah Kellen
|
| Carolyn | Victim/Witness |
Testified at trial about receiving calls for sexualized massages
|
| Sarah Kellen | Epstein Employee |
Personal assistant to Epstein; contacted victim Carolyn to schedule sexualized massages
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| S.D.N.Y. |
Southern District of New York (District Court cited in legal precedent)
|
|
| Coleman Com. Carrier, Inc. |
Cited in legal precedent case
|
Timeline (2 events)
Relationships (3)
conspiracies... involved the defendant and Epstein
Sarah Kellen, who worked as a personal assistant to Epstein
Carolyn, testified about receiving such calls from Sarah Kellen
Key Quotes (3)
"Epstein’s employees participated in contacting a minor victim to schedule appointments for sexualized massages."Source
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Quote #1
"Carolyn, testified about receiving such calls from Sarah Kellen, who worked as a personal assistant to Epstein."Source
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Quote #2
"The evidence at trial established that Kellen started working for Epstein in or about the early 2000s."Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (1,840 characters)
Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 31 of 51
2. Overt Acts
Counts Three and Five of the S2 Indictment charged different overt acts. There is no
overlap whatsoever in the overt acts between these two counts in the S2 Indictment. The defendant
does not appear to argue otherwise, (see Def. Mot. at 24), nor could she. The absence of
overlapping overt acts underscores the fact that these counts charged different conspiracies.
Accordingly, this factor weighs strongly against the defendant’s claim of multiplicity.
overlap whatsoever in the overt acts between these two counts in the S2 Indictment. The defendant
does not appear to argue otherwise, (see Def. Mot. at 24), nor could she. The absence of
overlapping overt acts underscores the fact that these counts charged different conspiracies.
Accordingly, this factor weighs strongly against the defendant’s claim of multiplicity.
3. Overlap in Participants
Turning to the overlap of participants, the evidence at trial established that some—but
importantly, not all—participants overlapped between the two conspiracy schemes charged in
Counts Three and Five. In any event, even if the participants had been identical in both
conspiracies, the identity of the participants alone would be insufficient to support a claim of
multiplicity. See United States v. Coleman Com. Carrier, Inc., 219 F. Supp. 2d 563, 565 (S.D.N.Y.
2002) (“[T]he existence of a single conduit does not establish proof of a single conspiracy[.]”)
(quoting Macchia, 35 F.3d at 669).
importantly, not all—participants overlapped between the two conspiracy schemes charged in
Counts Three and Five. In any event, even if the participants had been identical in both
conspiracies, the identity of the participants alone would be insufficient to support a claim of
multiplicity. See United States v. Coleman Com. Carrier, Inc., 219 F. Supp. 2d 563, 565 (S.D.N.Y.
2002) (“[T]he existence of a single conduit does not establish proof of a single conspiracy[.]”)
(quoting Macchia, 35 F.3d at 669).
Here, although the conspiracies charged in Counts Three and Five both involved the
defendant and Epstein, the S2 Indictment charged that, with respect to Count Five, Epstein’s
employees participated in contacting a minor victim to schedule appointments for sexualized
massages. See Dkt. No. 187, ¶ 25(d). At trial, a victim who testified under her first name, Carolyn,
testified about receiving such calls from Sarah Kellen, who worked as a personal assistant to
Epstein. (Tr. 1527). The evidence at trial established that Kellen started working for Epstein in
or about the early 2000s. (See, e.g., Tr. 832, 1889). Carolyn also testified about an incident in
defendant and Epstein, the S2 Indictment charged that, with respect to Count Five, Epstein’s
employees participated in contacting a minor victim to schedule appointments for sexualized
massages. See Dkt. No. 187, ¶ 25(d). At trial, a victim who testified under her first name, Carolyn,
testified about receiving such calls from Sarah Kellen, who worked as a personal assistant to
Epstein. (Tr. 1527). The evidence at trial established that Kellen started working for Epstein in
or about the early 2000s. (See, e.g., Tr. 832, 1889). Carolyn also testified about an incident in
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DOJ-OGR-00009593
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