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gument as to why Count One was constructively amended is the same as her argument as to Count Three, and the Court's analysis would be the same. See Maxwell Br. at 16. 24 EFTA00156423 Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 25 of 45 1. The Court's instructions, the evidence at trial, and
jury convicted the Defendant on all three conspiracy counts, the Defendant now requests that the Court impose judgment on only one of these counts. Maxwell Br. at 19, Dkt. No. 600. The Government concedes that Counts One and Three are multiplicitous and agrees that the Court should not impose judgment on
the Defendant argues that testimony resulted in the "ultimate prejudice" because it led to the jury improperly convicting her on three of the four Mann Act counts. Maxwell Br. at 18. For the same reasons noted above, the Defendant was not prejudiced by the Court's response to the jury note because the
we have identified; others do not. 2sOn one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into high society, and it appears that at some time they were romantically in
he Mann Act. Sections 2422 and 2423 are more recent additions, which focus on children. All three sections are sometimes jointly referred to as the Mann Act. 5 EFTA00234521 A. Violations of the Mann Act: 18 U.S.C. 8§ 2421-2423 1. Knowledge of Age Is Not Required. The Mann Act criminalizes travelin
he Mann Act. Sections 2422 and 2423 are more recent additions, which focus on children. All three sections are sometimes jointly referred to as the Mann Act. 5 EFTA02857528 A person who knowingly transports an individual who.has not attained the age of 18 years in interstate or foreign commerce ... w
Page: EFTA02857524_p5 →we have identified; others do not. 'On one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into high society, and it appears that at some time they were romantically in
Page: EFTA02857524_p28 →Entities connected to both Robert Maxwell and Mann Act

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSON
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
New York
LOCATION
Vicky Ward
PERSON
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
United States
LOCATIONthe Southern District
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONGerald Lefcourt
PERSON
U.S. Virgin Islands
LOCATION
Kenneth Marra
PERSON
Stephen Hawking
PERSON