This document is a summation by Ms. Menninger in a legal case (1:20-cr-00330-PAE) filed on August 10, 2022. Ms. Menninger argues for reasonable doubt regarding Carolyn's involvement in Count Six, suggesting Carolyn added Ghislaine Maxwell to her story after financial difficulties. The summation also addresses the government's conspiracy theory involving Epstein and Maxwell arranging for underage females to travel to New York for sex acts, clarifying that Carolyn did not travel to New York and Annie Farmer's travel was independent of Ghislaine Maxwell.
| Name | Role | Context |
|---|---|---|
| Ms. Menninger | Speaker/Attorney |
Delivering a summation in a legal case.
|
| Carolyn |
Subject of Count Six, accused of adding Ghislaine to her story, did not travel to New York.
|
|
| Ghislaine |
Mentioned in relation to Carolyn's story, later identified as Ghislaine Maxwell.
|
|
| Judge Nathan | Judge |
Will explain the concept of conspiracy.
|
| Epstein |
Alleged co-conspirator with Maxwell to arrange sex acts with underage females.
|
|
| Maxwell |
Alleged co-conspirator with Epstein to arrange sex acts with underage females, later identified as Ghislaine Maxwell.
|
|
| Annie Farmer |
Came to New York, testified on the stand, went to New Mexico, her travel was not due to Ghislaine Maxwell.
|
|
| Kate |
Mentioned in relation to a violation of New York law.
|
|
| Ghislaine Maxwell |
Explicitly named as being added to Carolyn's case and as not being involved in Annie Farmer's travel to New York.
|
| Name | Type | Context |
|---|---|---|
| Southern District Reporters, P.C. | Company |
Court reporting service for the document.
|
| Location | Context |
|---|---|
|
Location for alleged sex acts, Carolyn did not travel there, Annie Farmer came there.
|
|
|
Annie Farmer went there after testifying.
|
"And Count Six only relates to Carolyn. So if you don't believe Carolyn or if you have a reasonable doubt about Carolyn adding Ghislaine to the story, you just acquit her on that charge, as well."Source
"And there are numerous reasons why you should have substantial reasonable doubt in this case."Source
"But before I get to that, let's talk about conspiracy. Judge Nathan will explain to you that conspiracy is an agreement to accomplish something unlawful, and the government's theory is that Epstein and Maxwell agreed that they would encourage or arrange for females under the age of 17 to travel to New York to engage in sex acts with Epstein, and New York law provides that an adult of someone under 17 cannot legally consent to have sexual contact."Source
"So, what did Annie Farmer and Kate and Carolyn have to do with that violation of New York law? Nothing. Carolyn never went to New York. She never traveled anywhere. Any suggestion that she was asked to travel was something she added in the last year after her first lawsuits were over and her money was gone and she was adding Ghislaine Maxwell to the case."Source
"Annie came to New York through no involvement of Ghislaine Maxwell. As she told you, quite clearly on the stand and after she went to New Mexico, nobody asked her to travel"Source
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