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Case 1:20-cr-00330-PAE Document600_ Filed 02/11/22 Page 19 of 37
Court Exhibit #15 (Dkt. 593 at 23) (emphasis added). Indeed, the only question the jury raised in
the Note was whether it would be sufficient to satisfy the second element if they found that Ms.
Maxwell helped arrange Jane’s return flight from New Mexico as opposed to her flight to New
Mexico. /d. Any sexual abuse that occurred in New Mexico was not a violation of New York
law and was therefore an entirely distinct offense from the one charged in the Indictment.
The corroborating evidence supports the interpretation that the jury did not credit Jane’s
testimony that Ms. 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 flight logs, there were only two trips that
Jane may have taken while she was under the age of 17, which was significant because to convict
under Count Four, the jury had to find that Jane was under 17 years old when the abuse took
place. The first was a trip from Palm Beach to New York (Teterboro) on November 11, 1996,
when Jane was 16 years old. GX-662-R at 44. The second was a trip from New York
(Teterboro) to Santa Fe, New Mexico on May 9, 1997, also when Jane was 16 years old. GX-
662-R at 48. The critical difference between the two trips was that Ms. Maxwell was not a
passenger on the first trip to New York but was a passenger on the second trip to New Mexico.
Given the text of the Jury Note, it is likely that the jurors decided that there was no
corroborating evidence that Ms. Maxwell was present for, or helped to arrange, any of Jane’s
trips to New York, but that the flight logs did corroborate that Ms. Maxwell was present for her
trip to New Mexico. Asa result, the jury began evaluating Ms. Maxwell’s involvement in the
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Document Details
| Filename | DOJ-OGR-00008943.jpg |
| File Size | 747.7 KB |
| OCR Confidence | 95.1% |
| Has Readable Text | Yes |
| Text Length | 2,208 characters |
| Indexed | 2026-02-03 17:39:46.985486 |