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697 KB
Extraction Summary
3
People
3
Organizations
4
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing (defense motion/brief)
File Size:
697 KB
Summary
This document is page 6 of a legal defense filing (Document 122) in the case against Ghislaine Maxwell, dated January 25, 2021. The defense argues that Counts One and Three of the indictment are 'clones' because they share identical participants (Epstein and Maxwell), time periods (1994-1997), and operations (enticing minors to travel for abuse). The text specifically details an allegation regarding 'Minor Victim-1' being transported from Florida to New York for sexual abuse at Epstein's New York residence.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Alleged Co-conspirator |
Described as an 'alleged co-conspirator' identical to Epstein in the indictment; accused of enticing victims.
|
| Jeffrey Epstein | Alleged Co-conspirator |
Described as an 'alleged co-conspirator' identical to Maxwell; accused of enticing victims to his residences.
|
| Minor Victim-1 | Victim |
Person enticed to travel from Florida to New York for sexual abuse.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government |
The party making the claims in the Superseding Indictment.
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| Second Circuit |
Referenced in the footnote regarding the 'multifactor test'.
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| D.C. Cir. |
Referenced in case citation United States v. Cooper.
|
Timeline (3 events)
Unspecified (during conspiracy timeframe)
Travel of Minor Victim-1 from Florida to New York for purposes of sexual abuse.
Florida to New York
Locations (4)
| Location | Context |
|---|---|
|
Specific location where Minor Victim-1 was allegedly sexually abused.
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Origin point of travel for Minor Victim-1.
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Destination of travel for Minor Victim-1.
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General locations in different states where victims were enticed to travel.
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Relationships (2)
Document states: 'The alleged co-conspirators, Epstein and Maxwell, are identical.'
Allegation that Maxwell knew and intended for the victim's grooming and subjection to sexual abuse.
Key Quotes (4)
"The alleged co-conspirators, Epstein and Maxwell, are identical."Source
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Quote #1
"The time period of the alleged conspiracies, 1994 to 1997, is identical."Source
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Quote #2
"Ms. Maxwell and Jeffrey Epstein 'enticed and caused minor victims to travel to Epstein’s residences in different states, which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.'"Source
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Quote #3
"Minor Victim-1 was enticed to travel from Florida to New York for purposes of sexually abusing her at the New York Residence in violation of New York Penal Law, Section 130.55."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,085 characters)
Case 1:20-cr-00330-AJN Document 122 Filed 01/25/21 Page 6 of 9
APPLICATION OF THE MULTIFACTOR TEST¹
Paragraph 14 of the Superseding Indictment (the first paragraph in Count Three)
incorporates by reference all of the factual allegations made in Count One. The government has,
therefore, based Count Three on the exact same factual allegations as Count One, rendering the
two counts clones of one another. The commonality between these counts is complete and fatal
to one of the alleged conspiracies.
incorporates by reference all of the factual allegations made in Count One. The government has,
therefore, based Count Three on the exact same factual allegations as Count One, rendering the
two counts clones of one another. The commonality between these counts is complete and fatal
to one of the alleged conspiracies.
I. The overlap of participants.
The alleged co-conspirators, Epstein and Maxwell, are identical. See Indictment ¶¶ 9 and
15. The accusers are identical. See id. ¶¶ 7 and 17.
The alleged co-conspirators, Epstein and Maxwell, are identical. See Indictment ¶¶ 9 and
15. The accusers are identical. See id. ¶¶ 7 and 17.
II. The overlap of time.
The time period of the alleged conspiracies, 1994 to 1997, is identical. See id. ¶¶ 1 and
15.
The time period of the alleged conspiracies, 1994 to 1997, is identical. See id. ¶¶ 1 and
15.
III. Similarity of operation.
The government claims, in paragraph 2 of Count One, that the operation was a “scheme
to abuse minor victims” and that Ms. Maxwell and Jeffrey Epstein “enticed and caused minor
victims to travel to Epstein’s residences in different states, which MAXWELL knew and
intended would result in their grooming for and subjection to sexual abuse.” Id. ¶ 2. This is the
identical “scheme” alleged, first by reference, and then explicitly, in Count Three: “Minor
Victim-1 was enticed to travel from Florida to New York for purposes of sexually abusing her at
the New York Residence in violation of New York Penal Law, Section 130.55.” Id. ¶ 17(b).
The government claims, in paragraph 2 of Count One, that the operation was a “scheme
to abuse minor victims” and that Ms. Maxwell and Jeffrey Epstein “enticed and caused minor
victims to travel to Epstein’s residences in different states, which MAXWELL knew and
intended would result in their grooming for and subjection to sexual abuse.” Id. ¶ 2. This is the
identical “scheme” alleged, first by reference, and then explicitly, in Count Three: “Minor
Victim-1 was enticed to travel from Florida to New York for purposes of sexually abusing her at
the New York Residence in violation of New York Penal Law, Section 130.55.” Id. ¶ 17(b).
_________________
¹ The first factor, an analysis of the criminal offenses charged in “successive indictments” is
inapplicable here because Ms. Maxwell has been charged with two § 371 conspiracies in the same
indictment. The multifactor test, however, remains applicable. See, e.g., United States v. Cooper, 886
F3d. 146, 155 (D.C. Cir. 2018) (appellate court applied the Second Circuit multifactor test to two
conspiracies charged in the same indictment and determined that the charges were multiplicitous,
remanding the case to the district court with directions to vacate one of the convictions).
¹ The first factor, an analysis of the criminal offenses charged in “successive indictments” is
inapplicable here because Ms. Maxwell has been charged with two § 371 conspiracies in the same
indictment. The multifactor test, however, remains applicable. See, e.g., United States v. Cooper, 886
F3d. 146, 155 (D.C. Cir. 2018) (appellate court applied the Second Circuit multifactor test to two
conspiracies charged in the same indictment and determined that the charges were multiplicitous,
remanding the case to the district court with directions to vacate one of the convictions).
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