DOJ-OGR-00009576.jpg
651 KB
Extraction Summary
4
People
2
Organizations
2
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Court filing / legal brief (case 1:20-cr-00330-pae)
File Size:
651 KB
Summary
This document is page 14 of a court filing (Document 621) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on February 25, 2022. It discusses a specific jury note sent during deliberations regarding 'Count Four' and whether aiding in the return flight of a victim named 'Jane' (but not the flight to New Mexico) constituted guilt if the intent was sexual activity. The text details the defense's attempt to add jury instructions to limit the scope of intent to New York, which the Court rejected.
People (4)
| Name | Role | Context |
|---|---|---|
| Defendant | Accused |
Referenced throughout regarding conviction arguments and jury notes (Refers to Ghislaine Maxwell based on Case No. 1:...
|
| Jane | Victim/Witness |
Subject of transportation to New Mexico and potential sexual activity
|
| The Court | Judicial Authority |
Judge presiding over the trial, issuing instructions, and ruling on defense requests
|
| The Jury | Fact Finder |
Deliberating body that sent a note regarding Count Four
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| DOJ |
Department of Justice (indicated by Bates stamp DOJ-OGR)
|
|
| Defense Counsel |
Filed a letter seeking reconsideration of the Court's response
|
Locations (2)
| Location | Context |
|---|---|
|
Location where Jane was transported to, allegedly to engage in sexual activity
|
|
|
Mentioned in defense proposal regarding intent for sexual activity
|
Key Quotes (3)
"Under Count Four, if the defendant aided in the transportation of Jane’s return flight, but not the flight to New Mexico, where/if the intent was for Jane to engage in sexual activity, can she be found guilty under the second element?"Source
DOJ-OGR-00009576.jpg
Quote #1
"the jury note was otherwise 'too difficult to parse factually and legally.'"Source
DOJ-OGR-00009576.jpg
Quote #2
"[a]n intent that Jane engage in sexual activity in any state other than New York cannot form the basis of these two elements of Counts Two and Four."Source
DOJ-OGR-00009576.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,904 characters)
Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 14 of 51
conviction outside of the scope of the S2 Indictment only if taken entirely in isolation and applied
by a jury that disobeyed the Court’s instructions.
by a jury that disobeyed the Court’s instructions.
b. The Second Jury Note
The defendant argues that, notwithstanding the tight connection between the Indictment,
evidence at trial, and jury instructions, the jury in fact actually convicted the defendant for
transporting Jane to New Mexico to engage in criminal sexual activity there. This argument relies
almost entirely on a single jury note.
evidence at trial, and jury instructions, the jury in fact actually convicted the defendant for
transporting Jane to New Mexico to engage in criminal sexual activity there. This argument relies
almost entirely on a single jury note.
During deliberations, the jury sent the following note:
Under Count Four, if the defendant aided in the transportation of Jane’s
return flight, but not the flight to New Mexico, where/if the intent was
for Jane to engage in sexual activity, can she be found guilty under the
second element?
return flight, but not the flight to New Mexico, where/if the intent was
for Jane to engage in sexual activity, can she be found guilty under the
second element?
(Tr. 3126). The note led to a lengthy discussion, at the conclusion of which the Court concluded
it should refer the jury back to the jury charge on the second element of Count Four because the
jury note was otherwise “too difficult to parse factually and legally.” (Tr. 3126-40).
it should refer the jury back to the jury charge on the second element of Count Four because the
jury note was otherwise “too difficult to parse factually and legally.” (Tr. 3126-40).
That night, the defense filed a letter seeking reconsideration of the Court’s response and
raising the possibility of a constructive amendment or prejudicial variance. (Dkt. No. 566 at 2-3).
The defense asked the Court to give an additional instruction in the morning. (Id. at 7). That
proposal instructed the jury as to the intent elements of Counts Two and Four, and ended with the
sentence that “[a]n intent that Jane engage in sexual activity in any state other than New York
cannot form the basis of these two elements of Counts Two and Four.” (Id.)
raising the possibility of a constructive amendment or prejudicial variance. (Dkt. No. 566 at 2-3).
The defense asked the Court to give an additional instruction in the morning. (Id. at 7). That
proposal instructed the jury as to the intent elements of Counts Two and Four, and ended with the
sentence that “[a]n intent that Jane engage in sexual activity in any state other than New York
cannot form the basis of these two elements of Counts Two and Four.” (Id.)
The Court rejected the defendant’s request. The Court noted that the jury did not inquire
about Count Two, so there was no basis to respond to the jury note with information about Count
about Count Two, so there was no basis to respond to the jury note with information about Count
13
DOJ-OGR-00009576
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document