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CAROLYN
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This document is a page from a court transcript of a summation by Ms. Moe in the case against Maxwell. The summation outlines three conspiracy counts, alleging that from 1994 to 2004, Maxwell conspired with Epstein to commit crimes against victims Jane, Carolyn, and Annie. Ms. Moe argues that Maxwell groomed Carolyn and Annie as part of an agreement to provide Epstein with underage girls for abuse, which constitutes the conspiracy.
This document is a page from a court transcript (summation by Ms. Moe) in the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The prosecutor argues that Maxwell knowingly transported a minor named 'Jane' (whom she met at a summer camp) across state lines for sexual abuse, emphasizing Maxwell's knowledge of Jane's age (under 17). It also references testimony from a victim named 'Kate' regarding an incident where Maxwell instructed her to wear a schoolgirl outfit for Epstein, establishing Maxwell's knowledge of Epstein's preferences.
This document is a page from a court transcript of a prosecutor's, Ms. Moe's, summation. She argues that the defendant, Maxwell, is guilty of Count Four: transporting a minor named Jane to New York for illegal sexual activity. Ms. Moe asserts that Maxwell arranged the travel, was on flights with Jane as confirmed by witness Juan Alessi and flight records, and thereby aided and abetted Epstein.
This document is a page from the summation (closing arguments) delivered by prosecutor Ms. Moe in the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The prosecutor argues that Maxwell enticed a minor victim referred to as 'Jane' to travel to New York via plane, using money, gifts, and school payments provided by Epstein as inducement. The text outlines the legal elements of the crime, asserting that Maxwell intended for Jane to engage in criminal sexual activity with Epstein, who was provided access to the underage girl for molestation rather than mentorship.
This document is a page from a court transcript of a summation given by Ms. Moe in the case against Maxwell. The prosecutor argues that Maxwell was an essential accomplice to Epstein, focusing on Count Two, which alleges Maxwell enticed a victim named Jane to travel across state lines to New York for sexual abuse. The argument is supported by Jane's testimony and corroborated by a witness, Juan Alessi, who saw Maxwell, Epstein, and Jane boarding a plane together.
This document is a legal summation from a court case, outlining Ghislaine Maxwell's activities between 1995 and 2004. It details her role in recruiting, grooming, and exploiting several young women, including Kate, Jane, Annie Farmer, Virginia Roberts, and Carolyn, for Jeffrey Epstein. The text describes a timeline of abuse, financial transactions from Epstein to Maxwell totaling over $23 million, and the evolution of the abuse into a 'pyramid scheme' where victims were incentivized to recruit their friends.
This document is a page from a court transcript (summation by Ms. Moe) filed in August 2022. It details evidence corroborating the testimony of a witness named Carolyn, specifically linking her to Epstein and Maxwell through FedEx invoices from 2002 and phone messages left at the Palm Beach house in 2004. The prosecutor argues that Maxwell's name on the FedEx invoices proves her involvement in the operation.
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) featuring the summation by Ms. Moe. The text details allegations of sexual abuse involving Epstein and Maxwell against minors named Jane, Annie, Virginia Roberts, and Carolyn, supported by evidence such as flight logs and FedEx records.
This document is a legal summation from a court case, filed on August 10, 2022, detailing the testimony regarding a victim named Annie. It describes how Ghislaine Maxwell and Jeffrey Epstein lured Annie to New Mexico under the false pretense of a scholarship trip, where Maxwell then engaged in grooming behaviors. The text recounts an incident at a movie theater where Epstein assaulted Annie, with Maxwell's full knowledge and complicity.
This document is a page from a court transcript featuring a summation by Ms. Moe regarding a diary entry written by a teenager named Annie. The text discusses how the diary illustrates the grooming process for sexual abuse, specifically mentioning interactions with Epstein, Maria, and Maxwell during a trip to the movies and subsequent events in 1996.
This document is a transcript of a prosecutor's (Ms. Moe) summation in the trial of Ghislaine Maxwell. The prosecutor recounts the testimonies of two victims, 'Jane' and Annie Farmer, to argue for Maxwell's guilt. The summary details how Jane was sexually exploited by Maxwell and Jeffrey Epstein, and how Epstein began grooming a 16-year-old Annie Farmer, establishing a pattern of predatory behavior.
This document is a page from a court transcript of a summation delivered by Ms. Moe (prosecution) in the Ghislaine Maxwell trial. The speaker details two specific flights in May 1997 and April 1998 where a minor victim, 'Jane,' traveled with Epstein and Maxwell to New Mexico and New York. The speaker also rebuts the defense's argument that the 'Jane' listed in the flight logs was actually an adult personal assistant with the same first name, citing pilot and DMV testimony as proof.
This document is an email dated October 21, 2021, from reporter Pete Brush of Law360 to Judge Nathan of the Southern District of New York. On behalf of a coalition of reporters from various news outlets, Brush expresses support for the Reporters Committee for Freedom of the Press's arguments against secret jury selection and vetting in the upcoming trial of USA v. Maxwell. The email underscores the press corps' interest in maintaining transparency in the judicial process.
This document is page 3 of a legal filing dated October 18, 2021, addressed to Judge Alison J. Nathan regarding the case of Ghislaine Maxwell. The defense argues they have received voluminous discovery materials (over 14,000 pages) from the government very recently (Oct 11-12), leaving insufficient time to review them before filing motions in limine. The document details the logistics of the hard drive deliveries to counsel in New York and Colorado, and to Ms. Maxwell at the MDC, while noting that some materials provided to Maxwell were incomplete.
This document is a letter dated October 14, 2021, from attorney Jeffrey Pagliuca to Judge Alison J. Nathan, confirming November 15, 2021, as the deadline for Ghislaine Maxwell to file a motion under Federal Rule of Evidence 412 concerning the admissibility of evidence of an alleged victim's sexual behavior, clarifying its distinction from a motion in limine and its specific procedural requirements.
This document is page 8 of a legal defense filing (Document 342) from October 13, 2021, in the case against Ghislaine Maxwell. The text argues that a robust jury questionnaire and individual voir dire are necessary because the jury pool has been tainted by 'pervasive, vitriolic, and extreme' negative media coverage. The defense compares Maxwell's situation to other high-profile New York sex scandals (citing politicians and media figures) to illustrate the hostile environment and potential for juror bias.
This legal document, part of a court filing, argues that Ghislaine Maxwell's ability to receive a fair trial has been compromised by extensive negative publicity. The publicity stems from Jeffrey Epstein's 2008 case, the subsequent investigation by the Department of Justice's OPR, and the resignation of Alex Acosta. The document further contends that the trial's location in New York, a venue for other high-profile sex abuse cases involving figures like Andrew Cuomo, Harvey Weinstein, and R. Kelly, contributes to a biased environment.
This document is a narrative account from a legal filing, describing the author's interaction with a woman named Maria, an artist. It details Maria's history with Epstein and Maxwell, explaining how she was introduced to Epstein through New York socialite Eileen Guggenheim and lawyer Bert Fields. The text highlights Maria's fear of Epstein, her distrust following an experience with Vanity Fair, and how Epstein ultimately hired her for a job at his New York City mansion.
This document is page 7 of a legal filing (Document 171) dated March 23, 2021, in the case against Ghislaine Maxwell. The defense argues for her release on bail, claiming she has transparently disclosed her assets (including those held jointly with her spouse) and refuting the government's claim that her wealth makes her a flight risk. A footnote strongly condemns the government's suggestion that defense attorneys would allow escrowed legal funds to be used to support Maxwell as a fugitive.
This legal document, dated December 27, 2021, is a filing to Judge Alison J. Nathan arguing that the jury in Ms. Maxwell's trial is confused. The author contends that the court's response to a jury note improperly allows them to consider conduct that occurred in New Mexico as a basis for conviction on counts requiring a violation of New York law. The filing cites legal precedent to argue that New York lacks jurisdiction over conduct occurring entirely out-of-state and that this issue could warrant vacating a potential conviction.
This legal document, part of a court filing from December 2021, presents an argument from Ms. Maxwell's defense to Judge Alison J. Nathan. The defense contends that a supplemental jury instruction given by the court was incorrect and prejudicial, citing multiple Second Circuit precedents to argue that confusing or misleading instructions at a critical stage of deliberation can be grounds for reversal. The filing asserts that this error applies to multiple counts and requests a curative instruction.
This document is page 4 of a legal submission to Judge Alison J. Nathan (dated Dec 27, 2021) in the case of United States v. Ghislaine Maxwell. The text argues that the jury must be instructed not to convict Maxwell on Count Four based on the victim 'Jane's' travel to New Mexico, as the indictment specifically charged travel to New York. The defense contends that a conviction based on the New Mexico events would constitute a 'constructive amendment' or 'variance' from the indictment, which is reversible error.
This legal document outlines several overt acts related to Count Five of an indictment against Maxwell. It details the alleged recruitment and exploitation of a minor named Carolyn by Maxwell and Epstein between 2001 and 2004, including arranging travel, paying for sex acts, and encouraging her to recruit other girls. The document also mentions a separate incident involving another victim, Annie, in 1996, and explains the legal standard for proving an overt act in a conspiracy case.
This document is a page from the jury instructions in the trial of United States v. Ghislaine Maxwell, filed on December 19, 2021. It outlines 'Instruction No. 36' regarding the 'overt act' requirement for conspiracy charges. The text explicitly lists alleged overt acts involving Maxwell and Epstein, including group sexual encounters with a minor ('Jane'), enticing a minor to travel for sexual abuse, and an unsolicited massage given by Maxwell to 'Annie' in New Mexico.
This legal document is a jury instruction for Count Four in the case against Ms. Maxwell, concerning the transportation of an individual under 17 for illegal sexual activity. It details the second element the government must prove: that Ms. Maxwell knowingly transported 'Jane' across state lines with the intent for her to engage in sexual activity. The instruction clarifies that this illegal purpose need not be the sole reason for the travel, but must be a 'significant or motivating purpose' and not merely incidental.
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