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- {
- "document_metadata": {
- "page_number": "12",
- "document_number": "657",
- "date": "04/29/22",
- "document_type": "court document",
- "has_handwriting": false,
- "has_stamps": false
- },
- "full_text": "Case 22-1426, Document 58, 02/28/2023, 3475901, Page169 of 221\nA-369\nCase 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 12 of 45\na decade,\" having both the \"earlier phase\" and the later \"pyramid scheme.\" Trial Tr. at 40; see\nalso, e.g., id. at 2886 (describing 2001 as \"the beginning of the pyramid scheme of abuse\"). But\na single conspiracy can enter \"two or more phases or spheres of operation\" without creating a\ndiscontinuity in the underlying unlawful agreement, particularly if the same people are serving\nthe same roles in each phase. United States v. Pena, 846 F. App'x 49, 51 (2d Cir. 2021)\n(summary order) (quoting United States v. Berger, 224 F.3d 107, 114-15 (2d Cir. 2000)); see\nalso United States v. Maldonado-Rivera, 922 F.2d 934, 963 (2d Cir. 1990). Notably, the\nGovernment, after distinguishing between earlier and later phases in the pattern of abuse,\nimmediately emphasized that \"[f]or a decade, the defendant played an essential role in this\nscheme,\" blurring any difference between the two phases. Trial Tr. at 41.\nMoreover, though these phases did involve some differing means to acquire minor\nvictims, the differences presented at trial were not as great as the Government suggests in its\nbrief. As to both counts, both before and after 2001, the Government emphasized that massage\nwas a primary means by which the Defendant and Epstein normalized bodily contact and also the\nmeans by which the Defendant and Epstein commonly instigated instances of sexual abuse.\nCompare id. at 40 (\"You will learn that in the 1990s, they used the cover of mentoring young\ngirls . . . to introduce massage . . . and that you will learn that they used these so called massages\nas a way to sexually abuse the victims.\"), with id. at 41 (\"Under this pyramid scheme of abuse,\nthe defendant could just call girls to schedule massage appointments and hand them cash\nafterwards . . .\"), e.g., id. at 35 (\"You will learn that the cover of massage was the primary way\nthe defendant and Epstein lured girls into sexual abuse.\"), 2852 (\"Again and again throughout\nthis trial, you heard about how these girls were asked to perform sexualized massages on Jeffrey\nEpstein.\").\n12\nDOJ-OGR-00020995",
- "text_blocks": [
- {
- "type": "printed",
- "content": "Case 22-1426, Document 58, 02/28/2023, 3475901, Page169 of 221",
- "position": "header"
- },
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- "type": "printed",
- "content": "A-369",
- "position": "header"
- },
- {
- "type": "printed",
- "content": "Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 12 of 45",
- "position": "header"
- },
- {
- "type": "printed",
- "content": "a decade,\" having both the \"earlier phase\" and the later \"pyramid scheme.\" Trial Tr. at 40; see\nalso, e.g., id. at 2886 (describing 2001 as \"the beginning of the pyramid scheme of abuse\"). But\na single conspiracy can enter \"two or more phases or spheres of operation\" without creating a\ndiscontinuity in the underlying unlawful agreement, particularly if the same people are serving\nthe same roles in each phase. United States v. Pena, 846 F. App'x 49, 51 (2d Cir. 2021)\n(summary order) (quoting United States v. Berger, 224 F.3d 107, 114-15 (2d Cir. 2000)); see\nalso United States v. Maldonado-Rivera, 922 F.2d 934, 963 (2d Cir. 1990). Notably, the\nGovernment, after distinguishing between earlier and later phases in the pattern of abuse,\nimmediately emphasized that \"[f]or a decade, the defendant played an essential role in this\nscheme,\" blurring any difference between the two phases. Trial Tr. at 41.\nMoreover, though these phases did involve some differing means to acquire minor\nvictims, the differences presented at trial were not as great as the Government suggests in its\nbrief. As to both counts, both before and after 2001, the Government emphasized that massage\nwas a primary means by which the Defendant and Epstein normalized bodily contact and also the\nmeans by which the Defendant and Epstein commonly instigated instances of sexual abuse.\nCompare id. at 40 (\"You will learn that in the 1990s, they used the cover of mentoring young\ngirls . . . to introduce massage . . . and that you will learn that they used these so called massages\nas a way to sexually abuse the victims.\"), with id. at 41 (\"Under this pyramid scheme of abuse,\nthe defendant could just call girls to schedule massage appointments and hand them cash\nafterwards . . .\"), e.g., id. at 35 (\"You will learn that the cover of massage was the primary way\nthe defendant and Epstein lured girls into sexual abuse.\"), 2852 (\"Again and again throughout\nthis trial, you heard about how these girls were asked to perform sexualized massages on Jeffrey\nEpstein.\").",
- "position": "body"
- },
- {
- "type": "printed",
- "content": "12",
- "position": "footer"
- },
- {
- "type": "printed",
- "content": "DOJ-OGR-00020995",
- "position": "footer"
- }
- ],
- "entities": {
- "people": [
- "Jeffrey Epstein"
- ],
- "organizations": [
- "Government"
- ],
- "locations": [],
- "dates": [
- "02/28/2023",
- "04/29/22",
- "2001",
- "1990"
- ],
- "reference_numbers": [
- "Case 22-1426",
- "Document 58",
- "Case 1:20-cr-00330-AJN",
- "Document 657",
- "3475901",
- "A-369",
- "DOJ-OGR-00020995"
- ]
- },
- "additional_notes": "The document appears to be a court filing related to a case involving Jeffrey Epstein. The text discusses the defendant's role in a conspiracy and the use of massage as a means to normalize bodily contact and instigate sexual abuse. The document is a printed court document with no handwritten text or stamps."
- }
|