mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00013833.json

{
  "document_metadata": {
    "page_number": "242",
    "document_number": "759",
    "date": "08/10/22",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-PAE Document 759 Filed 08/10/22 Page 242 of 267 2270 LCAVMAX8\n1 Ghislaine to have Ghislaine arrange the travel. But she didn't even offer it herself. It seems like the best we have on this record is that she performed a ministerial function of arranging the travel. But that is not doing something, a cause, that produces an effect; that is simply doing paperwork.\n2 That is not what the statute was designed to criminalize.\n3 There has to be some effort to entice or persuade or induce somebody to travel, which we do not have on this record.\n4 And one case I would direct your Honor to is United States v. Joseph, 542 F.3d 13 (2d Cir. 2008). In that case, the Second Circuit reversed the conviction for enticement under this same statute, 2422, because the jury was instructed that they could convict if they found the defendant made the possibility of a sex act \"more appealing,\" as if that was enough to entice, if they made it more appealing.\n5 The court held that that was not enough to establish persuasion, inducement, enticement under the statute. And here we don't even have that. We just have her performing what a travel agent would do, which is arranging travel plans. And that is not enough, under the wording of the statute, to prove enticement. And there is nothing also from any member of the conspiracy on that same count, your Honor, doing anything to arrange or induce the travel.\n6 So I would argue, your Honor, that on the record we have before us, there is insufficient evidence to establish\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00013833",
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      "content": "1 Ghislaine to have Ghislaine arrange the travel. But she didn't even offer it herself. It seems like the best we have on this record is that she performed a ministerial function of arranging the travel. But that is not doing something, a cause, that produces an effect; that is simply doing paperwork.\n2 That is not what the statute was designed to criminalize.\n3 There has to be some effort to entice or persuade or induce somebody to travel, which we do not have on this record.\n4 And one case I would direct your Honor to is United States v. Joseph, 542 F.3d 13 (2d Cir. 2008). In that case, the Second Circuit reversed the conviction for enticement under this same statute, 2422, because the jury was instructed that they could convict if they found the defendant made the possibility of a sex act \"more appealing,\" as if that was enough to entice, if they made it more appealing.\n5 The court held that that was not enough to establish persuasion, inducement, enticement under the statute. And here we don't even have that. We just have her performing what a travel agent would do, which is arranging travel plans. And that is not enough, under the wording of the statute, to prove enticement. And there is nothing also from any member of the conspiracy on that same count, your Honor, doing anything to arrange or induce the travel.\n6 So I would argue, your Honor, that on the record we have before us, there is insufficient evidence to establish",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00013833",
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  ],
  "entities": {
    "people": [
      "Ghislaine",
      "Joseph"
    ],
    "organizations": [
      "Second Circuit",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22",
      "2008"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "759",
      "542 F.3d 13",
      "2422",
      "DOJ-OGR-00013833"
    ]
  },
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}