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CAROLYN
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This document is page 27 (numbered 26 internally) of jury instructions filed on December 19, 2021, in the case USA 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.' The instruction specifies that this count relates solely to a victim identified as 'Jane' during the time period of 1994 to 1997.
This legal document, filed on December 19, 2021, outlines the jury instructions for Count Two against Ms. Maxwell, which alleges a violation of New York Criminal Law. The count specifies that between 1994 and 1997, Ms. Maxwell enticed a minor named Jane across state lines for sexual activity, constituting Sexual Abuse in the Third Degree under New York Penal Law § 130.55. The document defines "sexual contact" and clarifies that under New York law, a person under seventeen is legally incapable of consent, but the prosecution must prove Ms. Maxwell knew of Jane's age.
This legal document, part of Case 1:20-cr-00330-PAE, provides jury instructions for Count Two against Ms. Maxwell, specifically focusing on the third element: "Enticement to Engage in Illegal Sexual Activity." It defines what constitutes acting "intentionally" and clarifies that the government must prove that a "significant or motivating purpose" for encouraging an individual named Jane to travel across state lines was for illegal sexual activity, not that it was the sole purpose.
This document is page 21 of a court filing (Document 565) from case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 19, 2021. It details Jury Instruction No. 14 regarding 'Count Two: Enticement to Engage in Illegal Sexual Activity,' outlining the three legal elements the Government must prove. It specifies that this count relates specifically to a victim identified as 'Jane' during the period of 1994 to 1997.
This document is a draft verdict sheet from the United States District Court for the Southern District of New York in the case against Ghislaine Maxwell. It lists the first three counts regarding conspiracy and enticement of minors for illegal sexual activity, providing spaces for the jury to mark 'Guilty' or 'Not Guilty'.
This document is a page from jury instructions (Instruction No. 36) filed on December 18, 2021, in the case against Ghislaine Maxwell. It details the 'Third Element' of conspiracy, requiring an 'overt act,' and lists specific alleged acts including group sexual encounters involving Maxwell, Epstein, and a minor named Jane (1994-1997), an unsolicited massage given by Maxwell to Annie in New Mexico (1996), and travel invitations to a minor named Carolyn (2001-2002).
This document is a page from a legal motion filed by Ghislaine Maxwell's defense team on February 4, 2021. The defense argues that the government has failed to provide a 'bill of particulars' specifying the dates and details of alleged interactions with 'Accuser-1' (Minor Victim 1), including travel from Florida to New York for sexual encounters with Jeffrey Epstein. Citing the legal precedent *Bortnovsky*, the defense claims Maxwell cannot adequately prepare for trial because the allegations span a four-year period without specific dates, despite the government claiming to possess corroborating flight and business records.
This document is a court transcript from August 10, 2022, where a witness named 'Jane' testifies about ceasing contact with Jeffrey Epstein at the end of 2002. She explains she stopped seeing him because she got engaged, which led to Epstein leaving 'increasingly agitated' voicemails demanding she call him back and reminding her that he was paying for her mother's apartment in New York.
This document is a page from a court transcript of the direct examination of a witness named "Jane". She testifies that during her senior year of high school, she continued to engage in unwanted "sexualized massages" with Jeffrey Epstein and also spent time with Ghislaine Maxwell. The witness states she moved away from New York in October 1999 after graduating.
This document is a court transcript page from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), featuring the direct examination of a witness identified as 'Jane'. Jane testifies about sexual abuse she endured at ages 14, 15, and 16 in the massage room of a New York house (implied to be Jeffrey Epstein's), confirming that Maxwell was present during those years. The testimony includes a detailed description of the massage room, noting it was off the master bathroom, very dark with red lighting, and contained a giant black massage table.
This document is a court transcript from a direct examination of a witness named Jane, filed on August 10, 2022. Jane describes her experience inside a house in New York, focusing on the artwork which she found creepy, dark, and intimidating, including paintings of naked women and orgies. She testifies that the atmosphere of the house made her feel unsafe and constantly watched.
This document is a page from a court transcript dated August 10, 2022, detailing the cross-examination of a witness named Visoski. The witness clarifies that Ghislaine's New York residence was at 116 East 65th Street and confirms that from 1991 through the 2000s, Ghislaine maintained a residence separate from Jeffrey Epstein's. The witness also states they would pick up luggage for both Ghislaine and Jeffrey Epstein, but from their respective residences.
This document is a page from the cross-examination of a witness named Visoski in the case US v. Maxwell (implied by case number). The testimony confirms that Visoski provided similar services for both Jeffrey Epstein and Ghislaine Maxwell, specifically handling luggage and installing audio/video equipment at their respective New York residences. The witness confirms Epstein resided at 9 East 71st Street and notes that Maxwell had several different New York residences between 1991 and 2005.
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) documenting the cross-examination of a witness named Visoski (likely Larry Visoski). The testimony establishes that Visoski began working for the subject (Epstein) in 1991 and utilized his mechanics background to install high-end audio/video equipment at all of the subject's properties, including New York, Palm Beach, Zorro Ranch, and 'the island.' The witness confirms the subject lived on 69th Street in New York in 1991.
This document is a page from the cross-examination transcript of a witness named Mr. Visoski. He is being questioned about his visits to Jeffrey Epstein's two New York residences between 1991 and 2005. Visoski confirms that his main reasons for visiting were to handle Epstein's luggage related to flights and to pursue his hobby of installing home theater systems.
This document is a page from a court transcript dated August 10, 2022, detailing the cross-examination of a witness named Visoski. The witness confirms staying in a New York building with Dave Rogers and seeing other 'Epstein employees' there, specifically identifying Sarah Kellen in a '66th Street building'. The questioning concludes on this topic before shifting to a ranch in New Mexico.
This document is a transcript of a court cross-examination of a witness named Visoski, filed on August 10, 2022. Visoski, who worked for Epstein, describes their lodging arrangements, stating they stayed at their own home near Palm Beach but were provided with a corporate apartment at 301 East 66th Street in New York, a building owned by Epstein. Visoski confirms that their partner and copilot, Dave Rogers, also stayed at the same New York location.
This document is page 117 of a court transcript (Summation by Ms. Menninger) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on August 10, 2022. The defense attorney argues against the credibility of a witness named Annie, highlighting inconsistencies between her testimony and statements made to the government in 2006 and 2020 regarding a trip to New Mexico and the nature of massages. The defense asserts that Epstein, not Maxwell, communicated with Annie's mother and that Maxwell was unaware of Epstein's hidden agenda.
This document is a transcript of a legal summation by Ms. Menninger, likely an attorney. Menninger argues that her client, Ghislaine Maxwell, had no involvement in a trip to New York taken by a person named Annie, stating the trip's purpose was for Annie to see her sister. To support this, Menninger asserts that Maxwell is never mentioned in Annie's diaries from that time and suggests that Annie's memories of events are unreliable and colored by hindsight.
This document is a legal summation describing the testimony of Ms. Menninger regarding two encounters with Epstein in New York. The first was a meeting with her sister in his office to discuss college applications, and the second was at a movie theater where he held her hand, an act she later reported to the Victims Compensation Fund as sexual abuse. The testimony also asserts that Ghislaine Maxwell was not present or involved in these events.
This document is a transcript of a legal summation by Ms. Menninger, likely for the defense. The speaker attempts to discredit two individuals: an unnamed woman by questioning her claims of secret flights and a $5 million payment from the government, and Annie Farmer by highlighting a court instruction that her alleged encounter with Epstein and Maxwell was not illegal as charged, and by noting that she was introduced to Epstein by her sister, Maria, who worked for him.
This document is a transcript from a legal summation by Ms. Menninger on August 10, 2022, arguing that a witness named Jane has an unreliable and 'contaminated' memory. The speaker presents evidence, including testimony from other witnesses (Annie, Larry Visoski) and a flight log, to contradict Jane's account of events involving Epstein's Santa Fe property. The summation alleges that Jane deliberately altered her timeline to make herself seem younger and that her memory was influenced by news reports and conversations with family.
This document is a transcript page from a defense summation by Ms. Menninger in a criminal trial (Case 1:20-cr-00330-PAE). The attorney argues that a witness's testimony is unreliable due to significant memory lapses and inconsistencies, specifically highlighting contradictory accounts given to the FBI versus in court regarding the location and circumstances of the first instance of sexual abuse involving Epstein.
This document is a page from a court transcript (summation by defense attorney Ms. Menninger filed 08/10/22) in the Ghislaine Maxwell case (Case 1:20-cr-00330-PAE). The attorney attacks the credibility of a witness named 'Jane' by highlighting inconsistencies in her testimony regarding dates, her age during specific trips (New York, New Mexico, Europe), and her communications with her mother regarding abuse versus other lawsuits. The text specifically mentions Jane receiving 'wads of cash' from Jeffrey Epstein and cites a 1997 flight log entry.
This document is a page from a court transcript of an opening statement by Ms. Sternheim. She describes Jeffrey Epstein's use of private jets as 'commuter jets' for a wide variety of guests, including friends, professionals, and girlfriends. Sternheim also outlines the relationship between Epstein and Ghislaine, stating that their personal 'companionship' ended, but Ghislaine continued to work for him as an employee.
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