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CAROLYN
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This document is page 103 of a court filing (Document 563) filed on December 18, 2021, containing Jury Instruction No. 14 for Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It outlines the three legal elements required to prove the Defendant guilty of 'Count Two: Enticement to Engage in Illegal Sexual Activity,' specifically noting that this count relates solely to an individual named 'Jane' between 1994 and 1997.
This document is a page from a legal filing (Case 1:20-cr-00330-PAE) detailing overt acts for Counts Three and Five of an indictment against Ghislaine Maxwell. It lists specific allegations of sexual abuse and recruitment involving minors named Jane and Carolyn between 1994 and 2004 in New York and Florida. The document is heavily edited with strike-throughs, notably removing allegations related to victims named Annie and Kate, and adjusting the age of victims from 17 to 18.
This document is a page from jury instructions (Instruction No. 36) in a federal criminal case, filed on December 18, 2021. It details the 'overt act' element required to prove a conspiracy charge, listing specific allegations from the indictment against conspirators Maxwell and Epstein. The alleged overt acts, occurring between 1994 and 2002, involve the sexual abuse and exploitation of underage victims identified as Jane, Annie, Kate, and Carolyn across multiple locations including New York, Florida, New Mexico, and London.
This document is page 31 of a court filing (Document 563) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on December 18, 2021. It outlines Jury Instruction No. 21 regarding Count Four: the transportation of a minor ('Jane') to engage in illegal sexual activity. The text clarifies the legal standard for intent, stating that the illegal activity must be a 'significant or motivating purpose' of the travel, though not necessarily the sole purpose, citing New York Penal Law Section 130.55.
This document is a page from the jury instructions (Instruction No. 19) filed on December 18, 2021, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It outlines the three legal elements required to prove 'Count Four: Transportation of an Individual Under the Age of 17 to Engage in Illegal Sexual Activity,' specifically relating to a victim identified as 'Jane' between 1994 and 1997. The text includes markup showing specific legal language adjustments, such as defining the age requirement and limiting the scope to interstate commerce.
This document is a jury instruction from a federal criminal case (1:20-cr-00330-PAE), filed on December 18, 2021. It details the third element of Count Two, "Enticement to Engage in Illegal Sexual Activity," which requires the government to prove Ms. Maxwell's intent. The instruction defines what constitutes acting "intentionally" and clarifies that the illegal activity must have been a "significant or motivating purpose" for encouraging the individual, Jane, to travel, rather than merely an incidental part of the trip.
This legal document is a jury instruction (Instruction No. 14) from case 1:20-cr-00330-PAE, filed on December 18, 2021. It details the three elements the government must prove beyond a reasonable doubt to convict the defendant on 'Count Two: Enticement to Engage in Illegal Sexual Activity'. The instruction specifies that this charge pertains exclusively to actions against an individual named 'Jane' between 1994 and 1997.
This legal document, part of an indictment, details overt acts related to a criminal case against Epstein and Maxwell. It outlines specific instances between 1994 and 2004 where they allegedly conspired to recruit and sexually abuse several minors, identified as Jane, Annie, Kate, and Carolyn, in various locations including New York, Florida, New Mexico, and London. The document describes methods of enticement, such as arranging travel and providing cash payments, and alleges that one victim, Carolyn, was also encouraged to recruit other girls.
This document outlines Jury Instruction No. 36 regarding the 'Third Element' of a conspiracy charge, specifically requiring proof of an 'overt act.' It details specific allegations from the indictment against Maxwell involving Epstein and victims identified as Jane, Annie, Kate, and Carolyn across various years and locations.
This legal document is a jury instruction (Instruction No. 21) from a court case filed on December 17, 2021. It pertains to Count Four, the transportation of a minor named Jane by Ms. Maxwell for illegal sexual activity. The instruction clarifies that for a conviction, the government must prove that a 'significant or motivating purpose' of the interstate travel was for illegal sexual activity, not necessarily the 'sole purpose'.
This document is a jury instruction from a legal case (1:20-cr-00330-PAE), filed on December 17, 2021. It details the third element of Count Two, 'Enticement to Engage in Illegal Sexual Activity,' specifically defining the legal standards for 'intent' and 'significant or motivating purpose' for the jury. The instruction clarifies that the prosecution (the Government) must prove beyond a reasonable doubt that a significant purpose of Ms. Maxwell encouraging 'Jane' to travel across state lines was for illegal sexual activity, and that this purpose was not merely incidental to the trip.
This legal document is a jury instruction (Instruction No. 14) from a court case filed on December 17, 2021. It details the three elements the Government must prove beyond a reasonable doubt to convict the Defendant on 'Count Two: Enticement to Engage in Illegal Sexual Activity'. The instruction specifies that this charge relates to actions involving an individual named 'Jane' between 1994 and 1997.
This document is a page from a court transcript, likely a judge's ruling, dated December 17, 2021. The speaker explains why a Non-Prosecution Agreement (NPA) is not being admitted as evidence, citing risks of prejudice, juror confusion, and undue delay that outweigh its relevance. The speaker also provides guidance that the government's prior charging decisions regarding Ms. Maxwell and Jeffrey Epstein are likely inadmissible.
This legal document, part of a court filing dated December 17, 2021, outlines the legal principles guiding the court's analysis of the government's investigation into Ms. Maxwell. It references precedents from the Second Circuit and the Supreme Court to establish rules regarding investigative techniques, challenges to government motives, and the admissibility of evidence related to charging decisions.
A legal letter from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the trial of Ghislaine Maxwell. The letter argues that the government used suggestive questioning techniques on accusers, specifically citing an instance where a witness named 'Jane' changed her testimony regarding a trip to New York and seeing 'The Lion King' after pressure from AUSA Rossmiller. The defense uses this to justify the necessity of expert testimony from Dr. Loftus regarding memory and suggestive questioning.
This legal document, filed on December 15, 2021, discusses the defendant's attempt to introduce statements from Robert Glassman to impeach a witness named Jane. The document details Jane's evolving testimony about a trip to New York with Epstein and the defendant to see 'The Lion King,' noting that her corrected recollections were communicated to the Government by her lawyer. The prosecution argues that Glassman's testimony on these same points is unnecessary and that questions about Jane's conversations with him were met with sustained objections.
This document is a page from a court transcript dated December 10, 2021, detailing a legal discussion between two attorneys, Mr. Rohrbach and Mr. Everdell, and the judge. The conversation centers on the admissibility and relevance of evidence concerning sexual conduct in New Mexico to a federal conspiracy charge under the Mann Act, particularly in relation to New York's age of consent laws. The judge acknowledges the complexity and indicates the need for a legally correct jury charge.
This document is a court transcript from case 1:20-cr-00330-PAE, filed on December 10, 2021. It captures a legal discussion between the court and Mr. Rohrbach regarding the definition of 'illegal sexual activity' in an indictment involving Mr. Epstein. The conversation centers on whether events in New Mexico constitute a crime under the Mann Act and how they relate to proving intent for illegal activity in New York, particularly concerning conspiracy charges against 'minor Victim 2'.
This court transcript from December 10, 2021, details a discussion between attorney Mr. Rohrbach and the judge regarding the legal framework of the case. They clarify that the charges are based on New York statutes, not New Mexico law, despite alleged sexual conduct occurring in New Mexico. The judge reiterates a prior instruction, explaining that because the witness was over the age of consent in New Mexico at the time, the conduct there was not illegal under local law, a point relevant for jury instruction.
This document is a court transcript from a hearing on December 10, 2021, in case 1:20-cr-00330-PAE. It captures a discussion between the government's attorney, Mr. Rohrbach, and the judge regarding jury instructions for an enticement charge. The core issue is whether the legality of sexual activity under New Mexico law is relevant or potentially prejudicial for a charge based on violating New York law, with the judge expressing concern about confusing the jury.
This document is page 33 of a court transcript from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE) dated December 10, 2021. Defense attorney Mr. Everdell argues that testimony regarding Accuser 2 and Accuser 3 might lead the jury to convict Maxwell on an improper basis because their allegations do not relate to New York law violations. The Court acknowledges the need to clarify to the jury that while evidence may be relevant to enticement charges, sexual activity in New Mexico cannot be considered as the illegal conduct charged in the indictment itself.
This is a page from a court transcript (Case 1:20-cr-00330-PAE, likely the Ghislaine Maxwell trial) filed on December 10, 2021. The Judge ('The Court') is discussing jury instructions regarding a specific witness involved in sexual conduct in New Mexico. The Judge notes that while the witness was above the age of consent in New Mexico, the government is using the evidence to prove enticement for illegal acts in New York, and the jury instructions must accurately reflect this legal distinction without favoring the government's arguments.
This document is page 8 of a defense filing in the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), dated December 5, 2021. The defense argues against the admission of government evidence, specifically photos of vibrators, a stuffed tiger, and a stuffed dog, claiming 'Jane' did not identify these specific items in her testimony. The defense also challenges photos of the interior of Epstein's New York apartment, arguing they are unauthenticated and potentially misleading.
This legal document, dated December 5, 2021, is a filing to Judge Alison J. Nathan arguing against the admissibility of interior photographs of Mr. Epstein's apartment. The author contends the photos, taken in 2019, cannot be proven to accurately represent the apartment's state during the charged conspiracy, which ended in 2004. The document highlights that the government's case for the photos' relevance relies solely on the testimony of a witness, "Jane," who described the apartment's interior based on her memory from an alleged visit in the mid-1990s.
This is a legal filing from the U.S. Department of Justice to Judge Alison J. Nathan, dated December 4, 2021, in the criminal case against Ghislaine Maxwell. The prosecution is moving to admit photographs from inside Jeffrey Epstein's New York residence as evidence. The government argues that these photographs are relevant to the case because they serve to corroborate the testimony of a witness identified by the pseudonym 'Jane'.
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