new mexico
LocationRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Accuser 2
|
Location of incident |
5
|
1 | |
|
person
Annie
|
Location of conduct |
5
|
1 | |
|
person
JANE
|
Travel incident location |
5
|
1 | |
|
person
Ms. Maxwell
|
Travel logistics |
5
|
1 | |
|
person
GHISLAINE MAXWELL
|
Location of alleged conduct |
1
|
1 |
DOJ-OGR-00010392.jpg
This document is page 26 of a court filing from United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 29, 2022. It discusses specific jury instructions regarding witnesses 'Jane,' 'Kate,' and 'Annie,' clarifying jurisdictional boundaries (New York vs. New Mexico) and age of consent issues relative to New York Penal Law Section 130.55. The text explains that while testimony from Kate (who was over 17) and Annie (whose incidents occurred in NM) could not be used as the sole basis for conviction on specific counts, it was admissible to establish the Defendant's intent regarding the transport of minors.
DOJ-OGR-00010390.jpg
This legal document is a court filing from Case 1:20-cr-00330-PAE, dated April 29, 2022. It addresses the Defendant's argument that her conviction was based on a 'constructive amendment' to the indictment, because a jury note suggested they found her guilty of intending a crime in New Mexico, rather than New York as charged. The court refutes this claim, concluding there is no 'substantial likelihood' that the Defendant was convicted of an offense different from the one in the indictment.
DOJ-OGR-00010387.jpg
This legal document, filed on April 29, 2022, is a court ruling denying a defendant's motions for acquittal and to vacate convictions. The ruling summarizes testimony from witnesses named Annie, Carolyn, and Kate, which established the Defendant's role in a conspiracy with Epstein to transport minors for illegal sexual activity. The evidence included the Defendant paying for sexualized massages, inappropriately touching a witness, and inviting underage girls to locations like New Mexico and Epstein's Caribbean island.
DOJ-OGR-00010379.jpg
This legal document details how the Defendant and Epstein used financial gifts and payments as a method of grooming victims like Jane and Annie, paying for things like lessons, school, and promising trips. The document also discusses the geographic scope of the criminal conspiracy, noting that while specific counts focused on New York and Florida, witnesses testified to sexual conduct occurring in New Mexico and London as well. The text highlights the testimony of victims, including Carolyn and Virginia Roberts, who were paid for sexualized massages.
DOJ-OGR-00010286.jpg
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.
DOJ-OGR-00010279.jpg
This document is page 13 of a legal filing (Document 647) from the case United States v. Ghislaine Maxwell, filed on March 11, 2022. The text argues that the jury was confused regarding the jurisdiction of New York state laws applied to conduct (sexual abuse of 'Jane') that occurred in New Mexico. The defense contends that the Court erred by declining a proposed supplemental instruction that would have clarified that Count Four requires an intent to violate New York law within New York, not merely sexual activity in New Mexico.
DOJ-OGR-00010278.jpg
This document is page 12 of a defense filing (Document 647) dated March 11, 2022, in the case against Ghislaine Maxwell. The text argues that the jury instructions were insufficient and led to a 'constructive amendment' of the indictment, potentially allowing the jury to convict Maxwell based on activity in New Mexico rather than the required New York jurisdiction. It highlights a 'Jury Note' demonstrating the jury's confusion regarding Count Four and the application of New York Penal Law Section 130.55.
DOJ-OGR-00010276.jpg
This document is page 10 of a legal filing from March 2022 in the US v. Maxwell case. The defense argues that a Jury Note regarding Count Four indicates the jury was considering convicting Maxwell based on intent for sexual activity occurring in New Mexico, which the defense claims raises a 'constructive amendment' issue. The text disputes the government's interpretation of the note, accusing the government of inserting a comma to alter the meaning and downplay the jury's focus on New Mexico.
DOJ-OGR-00010275.jpg
This legal document is a filing, likely from the defense, arguing that Ms. Maxwell's conviction on Count Four was improper. The argument centers on a 'Jury Note' which suggests the jury may have convicted her based solely on her intent for sexual activity to occur in New Mexico, without finding intent for abuse in New York, which the defense claims constitutes a 'constructive amendment' of the indictment. The filing accuses the government of mischaracterizing the Jury Note to obscure this issue.
DOJ-OGR-00010274.jpg
This document is a page from a legal filing (Case 1:20-cr-00330-PAE) dated March 11, 2022, arguing that the jury in the Ghislaine Maxwell trial had a fundamental misunderstanding of 'Count Four.' The defense argues that the jury asked if intent for sexual activity in New Mexico was sufficient for a conviction based on 'violation of New York law,' and asserts the Court failed to properly correct this misunderstanding.
DOJ-OGR-00010272.jpg
This document is page 6 of a legal filing (Document 647, filed March 11, 2022) in the criminal case against Ghislaine Maxwell. The defense argues that the jury may have erroneously convicted Maxwell on Counts One, Three, and Four based on a finding that she intended sexual activity to occur in New Mexico, rather than New York as required by law. The text cites a 'Jury Note' (Court Exhibit #15) as evidence that the jury was confused about the location requirement and asserts the Court failed to correct this misunderstanding.
DOJ-OGR-00010271.jpg
This legal document is a reply memorandum filed by Ghislaine Maxwell's defense team on March 11, 2022. The defense argues that the court's response to a jury note was erroneous, asserting that both the prosecution and defense agree that a conviction on the Mann Act counts required proving Maxwell's intent for illegal sexual activity to occur specifically within New York. The filing suggests that allowing for a conviction based on intent for activity in other locations, like New Mexico, would constitute a constructive amendment to the indictment.
DOJ-OGR-00009585.jpg
This document is page 23 of a legal filing (Document 621) in Case 1:20-cr-00330-PAE (USA v. Ghislaine Maxwell), filed on Feb 25, 2022. It argues that no legal 'variance' occurred during the trial regarding the charges in the S2 Indictment. The text discusses the grooming of a victim named 'Jane' between 1994 and 1997 and addresses the defendant's argument regarding prejudice concerning testimony about abuse at Epstein's ranch in New Mexico.
DOJ-OGR-00009584.jpg
This legal document, page 22 of a court filing from February 25, 2022, presents the prosecution's argument against the defendant's claim of a constructive amendment to their indictment. The prosecution asserts that the S2 Indictment for Mann Act offenses was consistent with the evidence presented and jury instructions, citing the D'Amelio case. A footnote further argues that even if one count was flawed, based on jury notes concerning Annie Farmer's testimony about abuse in New Mexico, it would not invalidate the other conspiracy counts, citing the Pfaff and Milstein cases.
DOJ-OGR-00009581.jpg
This legal document presents the defendant's speculation on a jury's split verdict, arguing that the conviction was based on a trip to New Mexico. The defense contends the jury acquitted on an enticement charge because flight logs, while placing the defendant on the trip, offered no proof she induced the victim, 'Jane', to go. The document contrasts this with a trip to New York, where Jane's testimony was corroborated by a flight record, and discusses the lack of evidence regarding the defendant's involvement in Jane's return travel from New Mexico.
DOJ-OGR-00009580.jpg
This document is page 18 of a legal filing (Document 621) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on February 25, 2022. The text is a legal argument refuting the defense's interpretation of a jury note regarding accomplice liability and flight arrangements. It specifically addresses the victim 'Jane', debating whether Maxwell arranged her return flight from New Mexico and discussing corroborating evidence in flight logs versus commercial flight records.
DOJ-OGR-00009578.jpg
This legal document, part of a court filing, argues that a jury note submitted during Ms. Maxwell's trial was ambiguous. The defense claimed the note referred to a specific 1997 flight to New Mexico, but this document contends the jury could have been referencing other flights or asking a different question entirely. The document concludes that the defendant's interpretation is 'mere conjecture' and supports the court's decision to reject the defense's arguments on this point.
DOJ-OGR-00009577.jpg
This legal document details a court's rejection of the defense's proposed jury instructions in a criminal case. The core dispute revolves around whether sexual activity with a minor named Jane in New Mexico is relevant to proving intent for a charge under New York law. The Court dismisses the defense's arguments as legally incorrect and refuses to alter its instructions to the jury based on the defense's interpretation of a jury note.
DOJ-OGR-00009576.jpg
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.
DOJ-OGR-00009575.jpg
This legal document, part of a court filing, refutes the defendant's argument that a constructive amendment occurred during trial. The prosecution argues that Jane's testimony about events in New Mexico was permissibly used to prove the defendant's intent for abuse to occur in New York. The document asserts that the jury was not erroneously convicted on a theory of guilt for crimes in New Mexico, as this was not pursued by the Government or allowed by jury instructions.
DOJ-OGR-00009573.jpg
This page is from a Government legal filing (Document 621, Case 1:20-cr-00330-PAE) arguing against a post-trial motion by the defendant (Ghislaine Maxwell). The Government asserts that the jury did not improperly convict the defendant based solely on sexual abuse of a victim named 'Jane' in New Mexico, but rather followed instructions regarding violations of New York law. The text discusses jury instructions, the lack of New Mexico specific legal charges presented to the jury, and refutes the defense's claim of a constructive amendment or variance.
DOJ-OGR-00003140.jpg
This legal document, page 206 of a court filing from April 16, 2021, is part of the government's argument against a defendant's motion. It contends that the indictment is sufficiently detailed, outlining the defendant's role in grooming three minor girls for sexual activity with Epstein in Florida, New Mexico, New York, and London between 1994 and 1997. The document also references the defendant's alleged perjury during a 2016 civil deposition and cites case law to support the legal sufficiency of the indictment.
DOJ-OGR-00003088.jpg
This document is a page from a government legal filing (Document 204) in the case against Ghislaine Maxwell. It includes excerpts from Maxwell's deposition where she denies interacting with anyone under 18 at Epstein's properties, other than Virginia [Giuffre]. The filing argues against the defense's motion to dismiss perjury charges based on ambiguity, asserting that terms like 'Jeffrey,' 'properties,' and 'interact' were clear in context.
DOJ-OGR-00014723.jpg
This document is a court transcript from August 10, 2022, capturing a legal argument between attorney Mr. Everdell and the presiding judge. Mr. Everdell argues that conduct and travel occurring solely in New Mexico cannot legally form the basis for a conviction of his client, Ms. Maxwell, under New York law, and he requests a supplemental jury instruction to this effect. The judge rejects the request, stating the proposed instruction is incorrect and that Mr. Everdell failed to seek to exclude the related testimony earlier.
DOJ-OGR-00014722.jpg
This document is a court transcript from August 10, 2022, capturing a dialogue between defense counsel, Mr. Everdell, and the Court. Mr. Everdell argues his interpretation of a recent note from the jury, contending that they are confused about whether they can convict his client, Ms. Maxwell, on Count Four based solely on events in New Mexico and are unclear on the jury instructions. The Court acknowledges his position but expresses skepticism about the assumptions being made.
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