{
  "document_metadata": {
    "page_number": "31",
    "document_number": "621",
    "date": "02/25/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 31 of 51\n\n2. Overt Acts\nCounts Three and Five of the S2 Indictment charged different overt acts. There is no overlap whatsoever in the overt acts between these two counts in the S2 Indictment. The defendant does not appear to argue otherwise, (see Def. Mot. at 24), nor could she. The absence of overlapping overt acts underscores the fact that these counts charged different conspiracies. Accordingly, this factor weighs strongly against the defendant's claim of multiplicity.\n\n3. Overlap in Participants\nTurning to the overlap of participants, the evidence at trial established that some—but importantly, not all—participants overlapped between the two conspiracy schemes charged in Counts Three and Five. In any event, even if the participants had been identical in both conspiracies, the identity of the participants alone would be insufficient to support a claim of multiplicity. See United States v. Coleman Com. Carrier, Inc., 219 F. Supp. 2d 563, 565 (S.D.N.Y. 2002) (“[T]he existence of a single conduit does not establish proof of a single conspiracy[.]”) (quoting Macchia, 35 F.3d at 669).\nHere, although the conspiracies charged in Counts Three and Five both involved the defendant and Epstein, the S2 Indictment charged that, with respect to Count Five, Epstein's employees participated in contacting a minor victim to schedule appointments for sexualized massages. See Dkt. No. 187, ¶ 25(d). At trial, a victim who testified under her first name, Carolyn, testified about receiving such calls from Sarah Kellen, who worked as a personal assistant to Epstein. (Tr. 1527). The evidence at trial established that Kellen started working for Epstein in or about the early 2000s. (See, e.g., Tr. 832, 1889). Carolyn also testified about an incident in\n\n30\n\nDOJ-OGR-00009593",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 31 of 51",
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    {
      "type": "printed",
      "content": "2. Overt Acts\nCounts Three and Five of the S2 Indictment charged different overt acts. There is no overlap whatsoever in the overt acts between these two counts in the S2 Indictment. The defendant does not appear to argue otherwise, (see Def. Mot. at 24), nor could she. The absence of overlapping overt acts underscores the fact that these counts charged different conspiracies. Accordingly, this factor weighs strongly against the defendant's claim of multiplicity.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "3. Overlap in Participants\nTurning to the overlap of participants, the evidence at trial established that some—but importantly, not all—participants overlapped between the two conspiracy schemes charged in Counts Three and Five. In any event, even if the participants had been identical in both conspiracies, the identity of the participants alone would be insufficient to support a claim of multiplicity. See United States v. Coleman Com. Carrier, Inc., 219 F. Supp. 2d 563, 565 (S.D.N.Y. 2002) (“[T]he existence of a single conduit does not establish proof of a single conspiracy[.]”) (quoting Macchia, 35 F.3d at 669).\nHere, although the conspiracies charged in Counts Three and Five both involved the defendant and Epstein, the S2 Indictment charged that, with respect to Count Five, Epstein's employees participated in contacting a minor victim to schedule appointments for sexualized massages. See Dkt. No. 187, ¶ 25(d). At trial, a victim who testified under her first name, Carolyn, testified about receiving such calls from Sarah Kellen, who worked as a personal assistant to Epstein. (Tr. 1527). The evidence at trial established that Kellen started working for Epstein in or about the early 2000s. (See, e.g., Tr. 832, 1889). Carolyn also testified about an incident in",
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    },
    {
      "type": "printed",
      "content": "30",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009593",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "defendant",
      "Epstein",
      "Carolyn",
      "Sarah Kellen"
    ],
    "organizations": [],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "02/25/22",
      "early 2000s"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "621",
      "Dkt. No. 187",
      "DOJ-OGR-00009593"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 31 of 51."
}