{
  "document_metadata": {
    "page_number": "9",
    "document_number": "293",
    "date": "05/25/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 9 of 32\nallegations of Accuser-4, alleging conduct that occurred \"[f]rom at least in or about 1994, up to and including in or about 2004.\" (Id. ¶¶ 11, 17).\nThe S2 Indictment also adds two new counts—Counts Five and Six—alleging that Ms. Maxwell violated and conspired to violate the federal sex trafficking statute, 18 U.S.C. § 1591. Count Five alleges that Ms. Maxwell conspired with Epstein and others to recruit “a person” knowing that the person “had not attained the age of 18 years and would be caused to engage in a commercial sex act” in violation of 18 U.S.C. § 1591(a). (Id. ¶¶ 23-24). Count Six charges Ms. Maxwell with a substantive violation of § 1591(a), claiming she “did recruit, entice, harbor, transport, provide, and obtain by any means” individuals who were under the age of 18, including Accuser-4, “who were then caused to engage in at least one commercial sex act with Jeffrey Epstein.” (Id. ¶ 27). Both counts are based on the allegations of Accuser-4 and allege conduct that purportedly occurred “[f]rom at least in or about 2001, up to and including in or about 2004.” (Id. ¶¶ 23, 27).\nARGUMENT\nI. The NPA Bars Ms. Maxwell’s Prosecution on Counts One, Three, Five, and Six.\nThe NPA bars any prosecution of Ms. Maxwell for the offenses charged in Counts One, Three, Five, and Six of the S2 Indictment. The Court has already concluded that the NPA bars prosecution for “three specific categories of offenses” deriving from the Florida Investigation:\n(1) ‘the offenses set out on pages 1 and 2’ of the NPA; namely, ‘any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007’ including five enumerated offenses;\n(2) ‘any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney’s Office’; and\n(3) ‘any offenses that arose from the Federal Grand Jury investigation.’\n5\nDOJ-OGR-00004274",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 9 of 32",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "allegations of Accuser-4, alleging conduct that occurred \"[f]rom at least in or about 1994, up to and including in or about 2004.\" (Id. ¶¶ 11, 17).\nThe S2 Indictment also adds two new counts—Counts Five and Six—alleging that Ms. Maxwell violated and conspired to violate the federal sex trafficking statute, 18 U.S.C. § 1591. Count Five alleges that Ms. Maxwell conspired with Epstein and others to recruit “a person” knowing that the person “had not attained the age of 18 years and would be caused to engage in a commercial sex act” in violation of 18 U.S.C. § 1591(a). (Id. ¶¶ 23-24). Count Six charges Ms. Maxwell with a substantive violation of § 1591(a), claiming she “did recruit, entice, harbor, transport, provide, and obtain by any means” individuals who were under the age of 18, including Accuser-4, “who were then caused to engage in at least one commercial sex act with Jeffrey Epstein.” (Id. ¶ 27). Both counts are based on the allegations of Accuser-4 and allege conduct that purportedly occurred “[f]rom at least in or about 2001, up to and including in or about 2004.” (Id. ¶¶ 23, 27).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "ARGUMENT",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I. The NPA Bars Ms. Maxwell’s Prosecution on Counts One, Three, Five, and Six.\nThe NPA bars any prosecution of Ms. Maxwell for the offenses charged in Counts One, Three, Five, and Six of the S2 Indictment. The Court has already concluded that the NPA bars prosecution for “three specific categories of offenses” deriving from the Florida Investigation:\n(1) ‘the offenses set out on pages 1 and 2’ of the NPA; namely, ‘any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007’ including five enumerated offenses;\n(2) ‘any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney’s Office’; and\n(3) ‘any offenses that arose from the Federal Grand Jury investigation.’",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004274",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Accuser-4",
      "Ms. Maxwell",
      "Epstein",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "Federal Bureau of Investigation",
      "United States Attorney's Office",
      "Federal Grand Jury"
    ],
    "locations": [
      "United States",
      "Florida"
    ],
    "dates": [
      "1994",
      "2001",
      "2004",
      "September 2007",
      "05/25/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 293",
      "18 U.S.C. § 1591",
      "DOJ-OGR-00004274"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ms. Maxwell, with references to various legal statutes and previous investigations."
}