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581 KB
Extraction Summary
3
People
3
Organizations
4
Locations
1
Events
1
Relationships
4
Quotes
Document Information
Type:
Court filing / legal memorandum
File Size:
581 KB
Summary
This document is a page from a defense motion (likely in the Ghislaine Maxwell trial, given the case number 1:20-cr-00330) filed on January 25, 2021. It argues that Count One and Count Three of the indictment are multiplicitous and violate the Double Jeopardy clause of the Fifth Amendment because they allege identical overt acts, geographic scope (NY, FL, NM, UK), and objectives. The filing concludes by requesting the Court dismiss one of the counts.
People (3)
| Name | Role | Context |
|---|---|---|
| Epstein | Alleged Co-conspirator / Owner of residences |
Mentioned in the context of 'minor victims to travel to Epstein’s residences'.
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| Macchia | Case Citation Subject |
Referenced in legal citation 'Macchia, 35 F.3d at 671' regarding legal standards for conspiracy.
|
| Minor victims | Victims |
Targets of the alleged conspiracies to be enticed and transported.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court |
Implied by the case header and 'The Court'.
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| The Government |
Prosecution, referred to as having alleged the conspiracies.
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| Department of Justice (DOJ) |
Indicated by the footer stamp 'DOJ-OGR'.
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Timeline (1 events)
2021-01-25
Filing of legal document arguing for dismissal of counts due to multiplicity.
Court Filing
Defense Counsel
The Court
Locations (4)
| Location | Context |
|---|---|
|
Listed as part of the geographic scope of the alleged conspiracies.
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Listed as part of the geographic scope of the alleged conspiracies.
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Listed as part of the geographic scope of the alleged conspiracies.
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Listed as part of the geographic scope of the alleged conspiracies.
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Relationships (1)
Text mentions victims traveling to Epstein's residences for the purpose of sexual abuse.
Key Quotes (4)
"The geographic scope is likewise identical: New York, Florida, New Mexico, and the United Kingdom."Source
DOJ-OGR-00002306(1).jpg
Quote #1
"the “objective” of the conspiracies was to entice and cause “minor victims to travel to Epstein’s residences in different states” for the purpose of sexual abuse."Source
DOJ-OGR-00002306(1).jpg
Quote #2
"The government has alleged the same conspiracy twice in violation of the Fifth Amendment to the United States Constitution."Source
DOJ-OGR-00002306(1).jpg
Quote #3
"The Court should therefore dismiss either Count One or Count Three of the Indictment as multiplicitous."Source
DOJ-OGR-00002306(1).jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,607 characters)
Case 1:20-cr-00330-AJN Document 122 Filed 01/25/21 Page 7 of 9
IV. The existence of common overt acts.
The overt acts alleged in Count 1, paragraph 11, are identical to those alleged in Count 3,
paragraph 17. See id. ¶¶ 3 and 17.
paragraph 17. See id. ¶¶ 3 and 17.
V. The geographic scope of the alleged conspiracies or location where overt acts
occurred.
occurred.
The geographic scope is likewise identical: New York, Florida, New Mexico, and the
United Kingdom. See id. ¶¶ 11 and 17.
United Kingdom. See id. ¶¶ 11 and 17.
VI. Common objectives.
As alleged in the Indictment, the “objective” of the conspiracies was to entice and cause
“minor victims to travel to Epstein’s residences in different states” for the purpose of sexual
abuse. See id. ¶¶ 2 and 17.
“minor victims to travel to Epstein’s residences in different states” for the purpose of sexual
abuse. See id. ¶¶ 2 and 17.
VII. The degree of interdependence between alleged distinct conspiracies.
This factor requires the Court to consider the extent to which the success or failure of one
alleged conspiracy is independent of a corresponding success or failure by the other. Macchia,
35 F.3d at 671. The conspiracy alleged in Count Three is logically dependent on the success of
the conspiracy alleged in Count One. The object of both, as claimed by the government, is to
first entice and then transport minors across state lines for the purpose of illegal sexual
activity. If the conspiracy to entice fails there would, logically, be no one to transport.
alleged conspiracy is independent of a corresponding success or failure by the other. Macchia,
35 F.3d at 671. The conspiracy alleged in Count Three is logically dependent on the success of
the conspiracy alleged in Count One. The object of both, as claimed by the government, is to
first entice and then transport minors across state lines for the purpose of illegal sexual
activity. If the conspiracy to entice fails there would, logically, be no one to transport.
CONCLUSION
The government has alleged the same conspiracy twice in violation of the Fifth
Amendment to the United States Constitution. The Court should therefore dismiss either Count
One or Count Three of the Indictment as multiplicitous.
Amendment to the United States Constitution. The Court should therefore dismiss either Count
One or Count Three of the Indictment as multiplicitous.
Dated: January 25, 2021
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DOJ-OGR-00002306
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