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Extracted Text (OCR)
Case 22-1426, Document 59, 02/28/2023, 3475902, Page93 of 113
410-1 at 19; Tr. 2758:23-2760:9.
Count Four rested exclusively on the testimony of Jane. Jane recalled
one trip to New Mexico when she was “15 or 16.” Tr. 321:6- 321:13. She flew
to New Mexico with Epstein and Maxwell and stayed at Epstein’s ranch. Tr.
321:14-322:6., and, while there, she was sexually abused. Tr. 322:7-323:19.
Based on Jane’s testimony and the Note, there is a substantial likelihood
that the jury improperly based its conviction solely on the sexual abuse that
Jane experienced in New Mexico. The jurors had the mistaken impression that
it would be sufficient to satisfy the second element of Count Four if they found
that Maxwell had intended Jane to engage in sexual activity in New Mexico,
even though such conduct was not and could not have been “sexual activity in
violation of New York Penal Law, Section 130.55.”
The corroborating evidence supports the theory that the jury did not
credit Jane’s testimony that Maxwell participated in or helped arrange Jane’s
sexual abuse in New York and was instead focused on her involvement in the
New Mexico conduct. The most important piece of evidence corroborating
Jane’s testimony were the flight logs kept by Epstein’s pilot, Dave Rodgers.
See GX-662-R. The flight logs were the only contemporaneous evidence
offered at trial that could corroborate that Jane, in fact, traveled to New York
and New Mexico and when those trips may have taken place. According to the
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Extracted Information
Dates
Document Details
| Filename | DOJ-OGR-00021140.jpg |
| File Size | 647.0 KB |
| OCR Confidence | 95.3% |
| Has Readable Text | Yes |
| Text Length | 1,525 characters |
| Indexed | 2026-02-03 20:07:39.932481 |