{
  "document_metadata": {
    "page_number": "4",
    "document_number": "286",
    "date": "05/20/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 286 Filed 05/20/21 Page 4 of 14\n\nGhislaine Maxwell respectfully submits this Reply Memorandum in Support of her Motion to Strike Surplusage from the Indictment (\"Motion\").\n\nIn its opposition (\"Opp.\") to Ms. Maxwell's Motion, the government concedes it cannot charge Ms. Maxwell with a substantive offense against Accuser-3 1 under either 18 U.S.C. § 2422(a) or 18 U.S.C. § 2423(a). It concedes that any such charge as to Accuser-3 would be time-barred. (Opp. 164). It concedes that it cannot show that either Ms. Maxwell or Jeffrey Epstein ever engaged, or sought to engage, in unlawful sexual activity with Accuser-3, who at all relevant times was above the legal age of consent in England, where all alleged activity as to Accuser-3 occurred. (Opp. 162 n.57.) And it concedes that it cannot establish that either Ms. Maxwell or Epstein ever caused, or sought to cause, Accuser-3 to travel while she was a minor. (Opp. 163 n.58.)\n\nYet the government argues that Ms. Maxwell and Epstein's alleged lawful interactions with Accuser-3 were somehow \"part of\" and \"in furtherance of\" a conspiracy to entice or cause underage girls to travel to engage in unlawful sexual activity with Epstein. Opp. 161, 163. The government's argument defies logic. The government does not and cannot explain how purported lawful, consensual sexual activity in England was part of an alleged conspiracy to cause minors to travel in the United States. Its eleventh-hour effort to salvage its allegations regarding Accuser-3 by proffering evidence that she [REDACTED]—evidence that the grand jury did not include in the Superseding Indictment (\"Indictment\")—does not establish the relevance of those allegations, given the government's inability to show that Accuser-3 [REDACTED].\n\n1 Accuser-3 is identified in the Superseding Indictment as \"Minor Victim-3.\" Similarly, the individuals identified in the Superseding Indictment as \"Minor Victim-1\" and \"Minor Victim-2\" are referred to herein as Accuser-1 and Accuser-2, respectively.\n\nDOJ-OGR-00004217",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 286 Filed 05/20/21 Page 4 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Ghislaine Maxwell respectfully submits this Reply Memorandum in Support of her Motion to Strike Surplusage from the Indictment (\"Motion\").",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In its opposition (\"Opp.\") to Ms. Maxwell's Motion, the government concedes it cannot charge Ms. Maxwell with a substantive offense against Accuser-3 1 under either 18 U.S.C. § 2422(a) or 18 U.S.C. § 2423(a). It concedes that any such charge as to Accuser-3 would be time-barred. (Opp. 164). It concedes that it cannot show that either Ms. Maxwell or Jeffrey Epstein ever engaged, or sought to engage, in unlawful sexual activity with Accuser-3, who at all relevant times was above the legal age of consent in England, where all alleged activity as to Accuser-3 occurred. (Opp. 162 n.57.) And it concedes that it cannot establish that either Ms. Maxwell or Epstein ever caused, or sought to cause, Accuser-3 to travel while she was a minor. (Opp. 163 n.58.)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Yet the government argues that Ms. Maxwell and Epstein's alleged lawful interactions with Accuser-3 were somehow \"part of\" and \"in furtherance of\" a conspiracy to entice or cause underage girls to travel to engage in unlawful sexual activity with Epstein. Opp. 161, 163. The government's argument defies logic. The government does not and cannot explain how purported lawful, consensual sexual activity in England was part of an alleged conspiracy to cause minors to travel in the United States. Its eleventh-hour effort to salvage its allegations regarding Accuser-3 by proffering evidence that she [REDACTED]—evidence that the grand jury did not include in the Superseding Indictment (\"Indictment\")—does not establish the relevance of those allegations, given the government's inability to show that Accuser-3 [REDACTED].",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 Accuser-3 is identified in the Superseding Indictment as \"Minor Victim-3.\" Similarly, the individuals identified in the Superseding Indictment as \"Minor Victim-1\" and \"Minor Victim-2\" are referred to herein as Accuser-1 and Accuser-2, respectively.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004217",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell",
      "Jeffrey Epstein",
      "Accuser-3",
      "Accuser-1",
      "Accuser-2"
    ],
    "organizations": [
      "DOJ"
    ],
    "locations": [
      "England",
      "United States"
    ],
    "dates": [
      "05/20/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 286",
      "DOJ-OGR-00004217"
    ]
  },
  "additional_notes": "The document contains redactions."
}