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698 KB

Extraction Summary

5
People
2
Organizations
1
Locations
2
Events
3
Relationships
3
Quotes

Document Information

Type: Legal filing / court document (government response or brief)
File Size: 698 KB
Summary

This document is page 10 of a legal filing (Document 621) from the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on February 25, 2022. It discusses the Court's jury instructions regarding the Mann Act, specifically focusing on whether the defendant intended for victims (referred to as 'Jane,' 'Kate,' and 'Annie') to engage in sexual activity in New York in violation of New York Penal Law Section 130.55. The text argues that the Court properly defined the scope of the alleged crimes and limited the jury's consideration to specific state offenses.

People (5)

Name Role Context
The Defendant Defendant
Subject of the trial and jury instructions (Ghislaine Maxwell, based on Case 1:20-cr-00330-PAE)
Jane Victim (Pseudonym)
Subject of substantive counts of enticement and transportation for sexual activity
Kate Witness/Victim (Pseudonym)
Mentioned in trial transcript citation (Tr. 1167-68)
Annie Witness/Victim (Pseudonym)
Mentioned in trial transcript citation (Tr. 2048-49)
The Court Judicial Authority
Issued jury instructions and rulings

Organizations (2)

Name Type Context
Second Circuit
Referenced in case citation regarding constructive amendment
DOJ
Department of Justice (implied by footer DOJ-OGR)

Timeline (2 events)

2022-02-25
Document Filed
Court
Various (During Trial)
Jury Instructions and Testimony
Courtroom
Defendant Jane Kate Annie

Locations (1)

Location Context
Location where sexual activity was intended to occur; jurisdiction of Penal Law

Relationships (3)

The Defendant Alleged Perpetrator/Victim Jane
Defendant accused of enticing/transporting Jane for sexual activity
The Defendant Defendant/Witness Kate
Trial transcript citation referencing Kate during defense requests
The Defendant Defendant/Witness Annie
Trial transcript citation referencing Annie during defense requests

Key Quotes (3)

"the defendant ‘enticed Jane to travel across state lines with the intent that she would engage in sexual activity for which a person could be charged with a crime under the penal law of New York State.’"
Source
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Quote #1
"For both Counts, the Court specifically instructed the jury on one and only one predicate state offense: a violation of New York Penal Law Section 130.55."
Source
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Quote #2
"the defendant knowingly transported Jane ‘with the intent that Jane engage in sexual activity for which any person can be charged with a criminal offense in violation of New York law.’"
Source
DOJ-OGR-00009572.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,052 characters)

Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 10 of 51
The Court’s Mann Act jury instructions also permitted the jury to determine only whether the defendant had intended that Jane (for the substantive counts) or the conspiracy victims were intended to engage in sexual activity in New York. During trial, the Court granted defense requests for limiting instructions at the time evidence came in to avoid the precise concern the defendant now articulates. (Tr. 1167-68 (Kate); 2048-49 (Annie)). See Gross, 2017 WL 4685111, at *27 (explaining that the Court identified no case “in which the Second Circuit has ever found a constructive amendment when a district court issued limiting instructions properly defining the scope of the alleged crime”). And at the conclusion of trial, the Court explained that Count Two alleged that the defendant “enticed Jane to travel across state lines with the intent that she would engage in sexual activity for which a person could be charged with a crime under the penal law of New York State.” (Tr. 3034; see Tr. 3031 (describing the third element of Count Two to require proof of an intent to violate “New York law as alleged in the indictment”)). Similarly, the Court explained that Count Four alleged that the defendant knowingly transported Jane “with the intent that Jane engage in sexual activity for which any person can be charged with a criminal offense in violation of New York law.” (Tr. 3037; see Tr. 3035 (describing the second element of Count Four to require proof of an intent to violate “New York law as alleged in the indictment”)). For both Counts, the Court specifically instructed the jury on one and only one predicate state offense: a violation of New York Penal Law Section 130.55. (Tr. 3034, 3037). The instructions on Counts One and Three incorporated this discussion of the elements of Counts Two and Four, and the only statute the Court identified in its discussion of the relevant overt acts was New York Penal Law Section 130.55. (Tr. 3049-50, 3056-57).
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