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732 KB
Extraction Summary
5
People
3
Organizations
6
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Court filing (legal motion/brief in criminal case)
File Size:
732 KB
Summary
This document is page 20 of a legal filing (Document 647) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on March 11, 2022. The text argues that 'Count Five' (related to Florida/Carolyn) is multiplicitous because it is a subset of the broader 'Count Three,' citing the lack of independent conspiracy. It references testimony from victims Jane, Kate, and Annie Farmer regarding sexual abuse at Epstein's properties in New Mexico, London, the US Virgin Islands, and Palm Beach.
People (5)
| Name | Role | Context |
|---|---|---|
| Jane | Witness/Victim |
Provided testimony regarding sexual abuse in Palm Beach; her testimony was relevant to Mann Act conspiracies.
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| Kate | Witness/Victim |
The jury heard testimony from her regarding conduct in Epstein's residences.
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| Annie Farmer | Witness/Victim |
The jury heard testimony from her regarding conduct in Epstein's residences.
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| Jeffrey Epstein | Perpetrator (Deceased) |
Mentioned as the owner of residences in New Mexico, London, USVI, and Florida where conduct took place.
|
| Carolyn | Witness/Victim |
Count Five was based on her allegations; she was not involved in Count Three overt acts.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court |
Implied by the case header and references to 'the Court'.
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| Second Circuit Court of Appeals |
Cited in legal precedent (2d Cir. 1992).
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| The Government |
The prosecution team arguing against the motion.
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Timeline (2 events)
Unknown (During Conspiracy)
Sexual abuse in Epstein's residences
New Mexico, London, U.S. Virgin Islands, Florida
Locations (6)
| Location | Context |
|---|---|
|
Location mentioned in relation to travel evidence and comparison to other locations.
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Location of one of Epstein's residences where conduct occurred.
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Location of one of Epstein's residences where conduct occurred.
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Location of one of Epstein's residences where conduct occurred.
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Geographic scope of Count Five; location of Epstein's Palm Beach residence.
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Specific city in Florida where Epstein's residence was located and sexual abuse occurred.
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Relationships (2)
Testimony described incidents of sexual abuse in Epstein's residence.
Count Five was based on Carolyn's allegations.
Key Quotes (3)
"Count Five did not describe a separate, independent conspiracy. Rather, it was a smaller subset of the broader overarching conspiracy charged in Count Three."Source
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Quote #1
"Counts Three and Five are therefore multiplicitous."Source
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Quote #2
"The Government cannot be permitted to retry defendants on smaller and smaller conspiracies, wholly contained within the scope of a large conspiracy, until it finds one small enough to be proved to the satisfaction of a jury."Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,177 characters)
Case 1:20-cr-00330-PAE Document 647 Filed 03/11/22 Page 20 of 24
repeatedly, and the Court agreed, that evidence of travel to locations other than New York, and
sexual abuse that occurred in those locations, was relevant to the Mann Act conspiracies. As a
result, the jury heard a great deal of testimony from Jane, Kate, and Annie Farmer, as well as
other evidence, about conduct that took place in Epstein’s residences in New Mexico, London,
the U.S. Virgin Islands, and, of course, Florida. Indeed, a large portion of Jane’s testimony,
which was relevant to the Mann Act conspiracies, described incidents of sexual abuse in
Epstein’s residence in Palm Beach that involved no interstate travel. (Tr. 298-315).
Accordingly, the geographic scope of Count Five (Florida) was included within the geographic
scope of Count Three.
sexual abuse that occurred in those locations, was relevant to the Mann Act conspiracies. As a
result, the jury heard a great deal of testimony from Jane, Kate, and Annie Farmer, as well as
other evidence, about conduct that took place in Epstein’s residences in New Mexico, London,
the U.S. Virgin Islands, and, of course, Florida. Indeed, a large portion of Jane’s testimony,
which was relevant to the Mann Act conspiracies, described incidents of sexual abuse in
Epstein’s residence in Palm Beach that involved no interstate travel. (Tr. 298-315).
Accordingly, the geographic scope of Count Five (Florida) was included within the geographic
scope of Count Three.
Count Five did not describe a separate, independent conspiracy. Rather, it was a smaller
subset of the broader overarching conspiracy charged in Count Three. Counts Three and Five
are therefore multiplicitous. See United States v. Calderone, 982 F.2d 42, 47-48 (2d Cir. 1992)
(finding two conspiracies were multiplicitous where, among other things, the time frame and
geographic scope of one conspiracy was entirely contained within the other conspiracy and the
core participants were the same); see also id. at 48 (“The Government cannot be permitted to
retry defendants on smaller and smaller conspiracies, wholly contained within the scope of a
large conspiracy, until it finds one small enough to be proved to the satisfaction of a jury.”).
subset of the broader overarching conspiracy charged in Count Three. Counts Three and Five
are therefore multiplicitous. See United States v. Calderone, 982 F.2d 42, 47-48 (2d Cir. 1992)
(finding two conspiracies were multiplicitous where, among other things, the time frame and
geographic scope of one conspiracy was entirely contained within the other conspiracy and the
core participants were the same); see also id. at 48 (“The Government cannot be permitted to
retry defendants on smaller and smaller conspiracies, wholly contained within the scope of a
large conspiracy, until it finds one small enough to be proved to the satisfaction of a jury.”).
C. Common Overt Acts
The government argues that the lack of common overt acts between Count Three and
Count Five indicates that they were different conspiracies. (Opp. at 30). As we explained in our
initial Motion, because Count Five was based on Carolyn’s allegations and did not involve Jane,
Kate, or Annie Farmer, that count alleged overt acts specific to Carolyn that were not alleged in
Count Three. (Mot. at 24; Ind. ¶¶ 25a-d, 19a-e). Nevertheless, because the conspiracy charged
in Count Five was a subset of the conspiracy charged in Count Three, as discussed above, the
Count Five indicates that they were different conspiracies. (Opp. at 30). As we explained in our
initial Motion, because Count Five was based on Carolyn’s allegations and did not involve Jane,
Kate, or Annie Farmer, that count alleged overt acts specific to Carolyn that were not alleged in
Count Three. (Mot. at 24; Ind. ¶¶ 25a-d, 19a-e). Nevertheless, because the conspiracy charged
in Count Five was a subset of the conspiracy charged in Count Three, as discussed above, the
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