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708 KB
Extraction Summary
3
People
3
Organizations
2
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Federal court filing / legal brief (page 15 of 37)
File Size:
708 KB
Summary
This document is page 15 of a legal filing (Document 600) from the case US v. Ghislaine Maxwell, filed on February 11, 2022. It outlines legal arguments regarding the Mann Act conspiracy charges, emphasizing that the government is bound to prove a violation of New York Penal Law Section 130.55 as the specific criminal object of the conspiracy. The text cites previous court transcripts and filings where the government conceded that the conviction depends specifically on the violation of New York law.
People (3)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Accused of intending for 'Jane' to engage in sex acts with Epstein.
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| Epstein | Co-conspirator / Associate |
Person with whom Jane was intended to engage in sex acts.
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| Jane | Victim (Pseudonym) |
Individual who traveled from Florida to New York for sex acts.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government |
Made statements to the Court regarding the scope of Mann Act counts.
|
|
| The Court |
Recipient of government representations regarding the case.
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|
| DOJ-OGR |
Department of Justice Office of Government Relations (referenced in Bates stamp).
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Timeline (2 events)
2021-11-01
Court transcript recording government statements on Mann Act conspiracies (Tr. 68:2-4)
Court
Locations (2)
| Location | Context |
|---|---|
|
Destination of travel; jurisdiction for Penal Law Section 130.55.
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|
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Origin of Jane's travel.
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Relationships (3)
Maxwell intended for Jane to engage in sex acts with Epstein.
Maxwell intended for Jane to travel for sex acts.
Key Quotes (4)
"Ms. Maxwell intended for her to engage in sex acts with Epstein 'in violation of New York Penal Law, Section 130.55.'"Source
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Quote #1
"The Government’s proposed instructions only permit the jury to convict on a violation of New York Penal Law Section 130.55."Source
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Quote #2
"Jane’s travel 'from Florida to New York, New York'"Source
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Quote #3
"the relevant illegal sexual activity has to be the violation of the New York offense."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,096 characters)
Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 15 of 37
wit” clauses that the charges were based on Jane’s travel “from Florida to New York, New
York” where Ms. Maxwell intended for her to engage in sex acts with Epstein “in violation of
New York Penal Law, Section 130.55.” Ind. ¶¶ 15, 21. The Mann Act conspiracy counts
(Counts One and Three) alleged generally that the object of the conspiracies was to entice or
cause underage girls to travel across state lines with the intent that they “engage in sexual
activity for which a person can be charged with a criminal offense.” Ind. ¶¶ 12, 18. However,
each count specified in the overt acts that the relevant criminal offense was a “violation of New
York Penal Law, Section 130.55.” Ind. ¶¶ 13b, 19b. See Attanasio, 870 F.2d at 816 (overt acts
can narrow the core of criminality of a conspiracy offense); Gross, 2017 WL 4685111, at *20
(“[A]lthough an indictment ‘drawn in general terms’ may articulate a broad core of criminality,
an indictment that is drawn in specific terms may be read to specify a narrower set of facts[.]”
(quoting Wozniak, 126 F.3d at 109-10)).
York” where Ms. Maxwell intended for her to engage in sex acts with Epstein “in violation of
New York Penal Law, Section 130.55.” Ind. ¶¶ 15, 21. The Mann Act conspiracy counts
(Counts One and Three) alleged generally that the object of the conspiracies was to entice or
cause underage girls to travel across state lines with the intent that they “engage in sexual
activity for which a person can be charged with a criminal offense.” Ind. ¶¶ 12, 18. However,
each count specified in the overt acts that the relevant criminal offense was a “violation of New
York Penal Law, Section 130.55.” Ind. ¶¶ 13b, 19b. See Attanasio, 870 F.2d at 816 (overt acts
can narrow the core of criminality of a conspiracy offense); Gross, 2017 WL 4685111, at *20
(“[A]lthough an indictment ‘drawn in general terms’ may articulate a broad core of criminality,
an indictment that is drawn in specific terms may be read to specify a narrower set of facts[.]”
(quoting Wozniak, 126 F.3d at 109-10)).
Even more important than the language of the Indictment were the government’s own
statements to the Court about the scope of the Mann Act counts. As set forth above, the
government consistently represented to the Court, in numerous conferences and filings, that a
conviction under the Mann Act counts had to be based on an intent or an agreement to violate
New York law, specifically New York Penal Law, Section 130.55. See, e.g., 11/1/2021 Tr. 68:2-
4 (“With respect to the Mann Act conspiracies, the particular criminal sexual activity relates to a
particular statute in New York.”); Dkt. 410-1 at 52 (“The Government’s proposed instructions
only permit the jury to convict on a violation of New York Penal Law Section 130.55.” (emphasis
added)); Tr. 2775:3-6 (“[A]t least as to these Mann Act charges, and the jury is going to be
instructed here that the relevant illegal sexual activity has to be the violation of the New York
offense.”).
statements to the Court about the scope of the Mann Act counts. As set forth above, the
government consistently represented to the Court, in numerous conferences and filings, that a
conviction under the Mann Act counts had to be based on an intent or an agreement to violate
New York law, specifically New York Penal Law, Section 130.55. See, e.g., 11/1/2021 Tr. 68:2-
4 (“With respect to the Mann Act conspiracies, the particular criminal sexual activity relates to a
particular statute in New York.”); Dkt. 410-1 at 52 (“The Government’s proposed instructions
only permit the jury to convict on a violation of New York Penal Law Section 130.55.” (emphasis
added)); Tr. 2775:3-6 (“[A]t least as to these Mann Act charges, and the jury is going to be
instructed here that the relevant illegal sexual activity has to be the violation of the New York
offense.”).
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