{
  "document_metadata": {
    "page_number": "188",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 188 of 239\n\nC. Discussion\nThe defendant's motion to strike should be denied—or at a minimum deferred until after the conclusion of the Government's direct case—because all of the challenged allegations pertain to evidence that will be relevant and admissible at trial, and are not unduly prejudicial.\nFirst, the allegations regarding Minor Victim-3 are properly included in the Indictment's description of the conspiracies charged in Counts One and Three because evidence of those incidents is relevant and admissible at trial as direct evidence of the crimes charged. Counts One and Three allege that the defendant participated in conspiracies with Epstein both to transport minor victims and to entice minor victims to travel with the intent to commit illegal sex acts. Indictment ¶¶ 9–11, 15–17. In the course and as part of those conspiracies, the defendant groomed multiple minor victims for sexual abuse by Epstein through multiple methods, including befriending victims and encouraging minor victims to provide massages to Epstein knowing he would engage in sex acts with them. Id. ¶¶ 1, 4, 7, 14. As detailed in the Indictment, that grooming was a fundamental part of both conspiracies because it encouraged minor victims to be alone with and to engage in sex acts with Epstein. Id. ¶¶ 1, 4, 14. It follows that the defendant's role grooming Minor Victim-3 to engage in sex acts with Epstein was a part of and therefore constitutes evidence of these conspiracies. Id. ¶¶ 7(c), 11(d), 17(d).\nThe defense claims that because the Indictment does not allege that each element of substantive violations of 18 U.S.C. §§ 2422 and 2423(a) was met as to Minor Victim-3, her experiences cannot be direct evidence of the conspiracies to violate those statutes charged in Counts One and Three. But that argument ignores a fundamental tenet of conspiracy law. It is axiomatic that a conspiracy does not require a completed substantive crime. See Salinas v. United States, 522 U.S. 52, 65 (1997) (“It is elementary that a conspiracy may exist and be punished whether or not the substantive crime ensures, for the conspiracy is a distinct evil, dangerous to the\n161\nDOJ-OGR-00003122",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 188 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "C. Discussion\nThe defendant's motion to strike should be denied—or at a minimum deferred until after the conclusion of the Government's direct case—because all of the challenged allegations pertain to evidence that will be relevant and admissible at trial, and are not unduly prejudicial.\nFirst, the allegations regarding Minor Victim-3 are properly included in the Indictment's description of the conspiracies charged in Counts One and Three because evidence of those incidents is relevant and admissible at trial as direct evidence of the crimes charged. Counts One and Three allege that the defendant participated in conspiracies with Epstein both to transport minor victims and to entice minor victims to travel with the intent to commit illegal sex acts. Indictment ¶¶ 9–11, 15–17. In the course and as part of those conspiracies, the defendant groomed multiple minor victims for sexual abuse by Epstein through multiple methods, including befriending victims and encouraging minor victims to provide massages to Epstein knowing he would engage in sex acts with them. Id. ¶¶ 1, 4, 7, 14. As detailed in the Indictment, that grooming was a fundamental part of both conspiracies because it encouraged minor victims to be alone with and to engage in sex acts with Epstein. Id. ¶¶ 1, 4, 14. It follows that the defendant's role grooming Minor Victim-3 to engage in sex acts with Epstein was a part of and therefore constitutes evidence of these conspiracies. Id. ¶¶ 7(c), 11(d), 17(d).\nThe defense claims that because the Indictment does not allege that each element of substantive violations of 18 U.S.C. §§ 2422 and 2423(a) was met as to Minor Victim-3, her experiences cannot be direct evidence of the conspiracies to violate those statutes charged in Counts One and Three. But that argument ignores a fundamental tenet of conspiracy law. It is axiomatic that a conspiracy does not require a completed substantive crime. See Salinas v. United States, 522 U.S. 52, 65 (1997) (“It is elementary that a conspiracy may exist and be punished whether or not the substantive crime ensures, for the conspiracy is a distinct evil, dangerous to the",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "161",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003122",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Minor Victim-3"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "04/16/21",
      "1997"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "18 U.S.C. §§ 2422 and 2423(a)",
      "522 U.S. 52"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein. The text discusses the defendant's motion to strike certain allegations and the government's response. The document is well-formatted and free of significant damage or redactions."
}