mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00010288.json

{
  "document_metadata": {
    "page_number": "22 of 24",
    "document_number": "647",
    "date": "03/11/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 647 Filed 03/11/22 Page 22 of 24\nthat Epstein gave her money after \"almost every visit\" to his home in Palm Beach. (Tr. 302).\nAnd both Jane and Annie Farmer testified about massages. (Tr. 308-11; 2083-86).\nThe government's attempt to characterize Count Three as an 'earlier scheme' and Count Five as a \"later pyramid scheme\" with different objects and methods is unavailing. (Opp. at 32).\nThe government's theory, as presented to the jury, was that Epstein and Ms. Maxwell engaged in a single conspiracy with a common method of operation and objective: to recruit and \"groom\" underage girls to sexually abuse them. That theory was entirely consistent with the evidence at trial. For these reasons, Counts Three and Five describe a single conspiracy, not multiple conspiracies, and are therefore multiplicitous. Accordingly, the Court should enter judgment only on Count Three.\nIII. The Court Should Grant Ms. Maxwell's Other Motions.\nFor the reasons already set forth in her initial Motion, the Court should vacate Ms. Maxwell's convictions as to all counts and dismiss the Indictment due to prejudicial pre-indictment delay. Further, the Court should enter a judgment of acquittal as to all counts under Rule 29 of the Federal Rules of Criminal Procedure because the government failed to prove each element of the charges beyond a reasonable doubt.\nCONCLUSION\nFor the foregoing reasons, Ms. Maxwell respectfully requests that the Court, in the alternative, (1) vacate Ms. Maxwell's convictions on the Mann Act counts (Counts One, Three, and Four) and grant a new trial under Rule 33 because the convictions were based on a constructive amendment and/or variance from the allegations in the Indictment, (2) enter judgment on only one of the three multiplicitous conspiracy counts - specifically, Count Three,\n18\nDOJ-OGR-00010288",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 647 Filed 03/11/22 Page 22 of 24",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "that Epstein gave her money after \"almost every visit\" to his home in Palm Beach. (Tr. 302).\nAnd both Jane and Annie Farmer testified about massages. (Tr. 308-11; 2083-86).\nThe government's attempt to characterize Count Three as an 'earlier scheme' and Count Five as a \"later pyramid scheme\" with different objects and methods is unavailing. (Opp. at 32).\nThe government's theory, as presented to the jury, was that Epstein and Ms. Maxwell engaged in a single conspiracy with a common method of operation and objective: to recruit and \"groom\" underage girls to sexually abuse them. That theory was entirely consistent with the evidence at trial. For these reasons, Counts Three and Five describe a single conspiracy, not multiple conspiracies, and are therefore multiplicitous. Accordingly, the Court should enter judgment only on Count Three.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "III. The Court Should Grant Ms. Maxwell's Other Motions.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "For the reasons already set forth in her initial Motion, the Court should vacate Ms. Maxwell's convictions as to all counts and dismiss the Indictment due to prejudicial pre-indictment delay. Further, the Court should enter a judgment of acquittal as to all counts under Rule 29 of the Federal Rules of Criminal Procedure because the government failed to prove each element of the charges beyond a reasonable doubt.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "CONCLUSION",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "For the foregoing reasons, Ms. Maxwell respectfully requests that the Court, in the alternative, (1) vacate Ms. Maxwell's convictions on the Mann Act counts (Counts One, Three, and Four) and grant a new trial under Rule 33 because the convictions were based on a constructive amendment and/or variance from the allegations in the Indictment, (2) enter judgment on only one of the three multiplicitous conspiracy counts - specifically, Count Three,",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "18",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010288",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Ms. Maxwell",
      "Jane",
      "Annie Farmer"
    ],
    "organizations": [],
    "locations": [
      "Palm Beach"
    ],
    "dates": [
      "03/11/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 647",
      "Counts One, Three, Four, Five",
      "Rule 29",
      "Rule 33",
      "DOJ-OGR-00010288"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, with references to various legal rules and procedures. The text is well-formatted and printed, with no visible handwriting or stamps."
}