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706 KB
Extraction Summary
10
People
1
Organizations
6
Locations
4
Events
5
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
706 KB
Summary
This legal document, part of a court filing, argues for the sufficiency of evidence to uphold a defendant's conviction on multiple counts. It details the defendant's role in facilitating Jeffrey Epstein's sex trafficking operation, specifically by making travel arrangements for a victim named Jane and recruiting another victim, Virginia. The document cites trial testimony and legal precedents to assert that a rational jury could and did find the defendant guilty.
People (10)
| Name | Role | Context |
|---|---|---|
| Annie |
Mentioned in testimony regarding shopping with the defendant in New Mexico and being taught to massage Epstein's feet.
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| Epstein |
Mentioned as the person whose feet Annie was taught to massage, whose Florida house Virginia was brought to, who Virg...
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| Virginia | Victim |
Mentioned as being recruited by the defendant, brought to Epstein's house by Alessi, and receiving money for sex with...
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| Alessi |
Mentioned as being instructed by the defendant to bring Virginia to Epstein's Florida house.
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| Carolyn |
Mentioned as being invited to travel.
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| Jane | Victim |
Mentioned as the subject of travel arrangements made by the defendant, including a trip from New York to Palm Beach o...
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| Jeffrey |
Mentioned as asking the defendant to make travel arrangements for Jane. This is likely Jeffrey Epstein.
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| Vargas-Cordon | Defendant in a cited case |
Mentioned in the case citation United States v. Vargas-Cordon.
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| Jaire | Victim in a cited case |
Mentioned in a quote from the Vargas-Cordon case as the person to whom sexual access was a dominant purpose of transp...
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| Mi Sun Cho | Defendant in a cited case |
Mentioned in the case citation United States v. Mi Sun Cho.
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Organizations (1)
| Name | Type | Context |
|---|---|---|
| United States | government agency |
Mentioned as the plaintiff in the cited cases United States v. Vargas-Cordon and United States v. Mi Sun Cho.
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Timeline (4 events)
Locations (6)
| Location | Context |
|---|---|
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Location where the defendant went shopping with Annie and taught her to massage Epstein's feet.
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Location of Epstein's house where Virginia was brought.
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Origin of Jane's travel and location of her abuse.
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Destination of Jane's travel from New York.
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Location of Vargas-Cordon's home in a cited case.
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Destination of transport in the cited Vargas-Cordon case.
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Relationships (5)
The document states Jeffrey (Epstein) would ask the defendant to make travel arrangements for Jane, and the defendant recruited Virginia for Epstein.
The defendant made travel arrangements for Jane and traveled with her on Epstein's private plane, participating in her abuse.
The document cites testimony that the defendant recruited Virginia for Epstein.
The document states the defendant instructed Alessi to bring Virginia to Epstein's house.
Key Quotes (5)
"assist"Source
— unnamed witness
(From testimony that the defendant would 'assist' in 'making travel arrangements'.)
DOJ-OGR-00009611.jpg
Quote #1
"making travel arrangements"Source
— unnamed witness
(From testimony that the defendant would assist in 'making travel arrangements'.)
DOJ-OGR-00009611.jpg
Quote #2
"[S]ometimes it would be – Jeffrey would ask her, hey, can you get Jane, you know, tickets and the times and whatnot and make the arrangements to be picked up."Source
— unnamed witness
(Testimony (Tr. 323-24) describing how Jeffrey Epstein would direct the defendant to arrange travel for Jane.)
DOJ-OGR-00009611.jpg
Quote #3
"The record is replete with evidence from which a reasonable jury could infer that sexual access to Jaire was a dominant purpose of Vargas-Cordon’s repeated transport of her from his New Jersey home into Brooklyn."Source
— 2d Cir. Court
(Quoted from the legal precedent United States v. Vargas-Cordon, 733 F.3d 336 (2d Cir. 2013).)
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Quote #4
"Cho does not dispute that one who arranges"Source
— 2d Cir. Court
(Quoted from the legal precedent United States v. Mi Sun Cho, 713 F.3d 716, 720 (2d Cir. 2013). The quote is incomplete in the document.)
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,065 characters)
Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 49 of 51
2080-84 (shopping with Annie in New Mexico and teaching her to massage Epstein’s feet), 840-45 (recruiting Virginia and instructing Alessi to bring her to Epstein’s Florida house), 1524 (Virginia receiving money for sex with Epstein), 1534 (inviting Carolyn to travel)). The jury evidently credited this testimony, and based on that testimony and the reasonable inferences from it, a rational jury easily could have (and did) find her guilty on Count One.
The defendant has made no substantive argument as to the sufficiency of the evidence on the remaining counts, and for good reason. Just as the conspiracies in Counts One and Three are multiplicitous because enticement and transportation are dual aims of the same conspiracy, see supra Part III, Count Three is amply supported by the evidence underlying Count One. As to Count Four, the record contains evidence that the defendant made travel arrangements for Jane, including the specific incident in which Jane had difficulty returning from New York to Palm Beach, and that the defendant traveled with Jane on Epstein’s private plane. (Tr. 2268-69; see Tr. 316-17 (testimony that the defendant traveled with Jane on Epstein’s private jet and would “assist” in “making travel arrangements”); Tr. 323-24 (“[S]ometimes it would be – Jeffrey would ask her, hey, can you get Jane, you know, tickets and the times and whatnot and make the arrangements to be picked up.”). That, in combination with evidence of the defendant’s participation in Jane’s abuse in New York, is sufficient on its own for the jury to convict on Count Four. See United States v. Vargas-Cordon, 733 F.3d 336 (2d Cir. 2013) (“The record is replete with evidence from which a reasonable jury could infer that sexual access to Jaire was a dominant purpose of Vargas-Cordon’s repeated transport of her from his New Jersey home into Brooklyn.”); United States v. Mi Sun Cho, 713 F.3d 716, 720 (2d Cir. 2013) (“Cho does not dispute that one who arranges
The defendant has made no substantive argument as to the sufficiency of the evidence on the remaining counts, and for good reason. Just as the conspiracies in Counts One and Three are multiplicitous because enticement and transportation are dual aims of the same conspiracy, see supra Part III, Count Three is amply supported by the evidence underlying Count One. As to Count Four, the record contains evidence that the defendant made travel arrangements for Jane, including the specific incident in which Jane had difficulty returning from New York to Palm Beach, and that the defendant traveled with Jane on Epstein’s private plane. (Tr. 2268-69; see Tr. 316-17 (testimony that the defendant traveled with Jane on Epstein’s private jet and would “assist” in “making travel arrangements”); Tr. 323-24 (“[S]ometimes it would be – Jeffrey would ask her, hey, can you get Jane, you know, tickets and the times and whatnot and make the arrangements to be picked up.”). That, in combination with evidence of the defendant’s participation in Jane’s abuse in New York, is sufficient on its own for the jury to convict on Count Four. See United States v. Vargas-Cordon, 733 F.3d 336 (2d Cir. 2013) (“The record is replete with evidence from which a reasonable jury could infer that sexual access to Jaire was a dominant purpose of Vargas-Cordon’s repeated transport of her from his New Jersey home into Brooklyn.”); United States v. Mi Sun Cho, 713 F.3d 716, 720 (2d Cir. 2013) (“Cho does not dispute that one who arranges
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