{
  "document_metadata": {
    "page_number": "8",
    "document_number": "286",
    "date": "05/20/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 286 Filed 05/20/21 Page 8 of 14\n\nThe government also improperly stretches the scope of the alleged conspiracies in a failing attempt to make its allegations regarding Accuser-3 fit within those charges. For example, the government asserts that Ms. Maxwell's alleged role in purported lawful sexual activity involving Epstein and Accuser-3 in England is \"evidence of the defendant's agreements with Epstein to identify minor girls to entice and transport for purposes of illegal sex acts.\" (Opp. 162.) But the Indictment does not allege that Ms. Maxwell conspired with Epstein to \"entice\" minor girls to commit illegal sex acts, let alone to \"identify minor girls\" for such an enticement. Nor could it, since mere \"enticement\" to commit illegal sex acts is insufficient to establish a Mann Act violation. The alleged conspiracies were conspiracies to entice or cause minors to travel for purposes of engaging in illegal sex acts, and the Indictment does not allege that Accuser-3 ever traveled or engaged in illegal sex acts.\n\nThe government commits a similar Freudian slip in its attempt to distinguish United States v. Hsia, 24 F. Supp. 2d 14 (D.D.C. 1998), when it states that \"the allegations regarding [Accuser-3] involve conduct that falls within the heartland of the conspiracy: grooming a minor girl to engage in sex acts with Jeffrey Epstein.\" Opp. 164 n.59. The \"heartland of the conspiracy\" is actual or contemplated interstate travel of minor girls to engage in unlawful sexual acts with Epstein, which the government cannot establish with respect to Accuser-3. The government's opposition repeatedly treats interstate travel, the linchpin of federal court jurisdiction over the alleged conduct and the necessary object of the conspiracies alleged, as a throwaway element of its case.\n\nIn short, neither the allegations regarding Accuser-3 nor the government's proffer establish an intent that Accuser-3 (i) engage in \"illegal sex acts\" or (ii) travel while a minor. The\n\n5\n\nDOJ-OGR-00004221",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 286 Filed 05/20/21 Page 8 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The government also improperly stretches the scope of the alleged conspiracies in a failing attempt to make its allegations regarding Accuser-3 fit within those charges. For example, the government asserts that Ms. Maxwell's alleged role in purported lawful sexual activity involving Epstein and Accuser-3 in England is \"evidence of the defendant's agreements with Epstein to identify minor girls to entice and transport for purposes of illegal sex acts.\" (Opp. 162.) But the Indictment does not allege that Ms. Maxwell conspired with Epstein to \"entice\" minor girls to commit illegal sex acts, let alone to \"identify minor girls\" for such an enticement. Nor could it, since mere \"enticement\" to commit illegal sex acts is insufficient to establish a Mann Act violation. The alleged conspiracies were conspiracies to entice or cause minors to travel for purposes of engaging in illegal sex acts, and the Indictment does not allege that Accuser-3 ever traveled or engaged in illegal sex acts.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "The government commits a similar Freudian slip in its attempt to distinguish United States v. Hsia, 24 F. Supp. 2d 14 (D.D.C. 1998), when it states that \"the allegations regarding [Accuser-3] involve conduct that falls within the heartland of the conspiracy: grooming a minor girl to engage in sex acts with Jeffrey Epstein.\" Opp. 164 n.59. The \"heartland of the conspiracy\" is actual or contemplated interstate travel of minor girls to engage in unlawful sexual acts with Epstein, which the government cannot establish with respect to Accuser-3. The government's opposition repeatedly treats interstate travel, the linchpin of federal court jurisdiction over the alleged conduct and the necessary object of the conspiracies alleged, as a throwaway element of its case.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "In short, neither the allegations regarding Accuser-3 nor the government's proffer establish an intent that Accuser-3 (i) engage in \"illegal sex acts\" or (ii) travel while a minor. The",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004221",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Epstein",
      "Jeffrey Epstein",
      "Accuser-3"
    ],
    "organizations": [
      "government"
    ],
    "locations": [
      "England",
      "D.D.C."
    ],
    "dates": [
      "05/20/21",
      "1998"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 286",
      "Opp. 162",
      "Opp. 164 n.59",
      "24 F. Supp. 2d 14",
      "DOJ-OGR-00004221"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, discussing allegations and legal arguments regarding Accuser-3 and Jeffrey Epstein. The text is printed and there are no visible stamps or handwritten notes."
}