EFTA00014982.pdf

111 KB
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Extraction Summary

5
People
2
Organizations
3
Locations
3
Events
3
Relationships
4
Quotes

Document Information

Type: Legal correspondence / letter
File Size: 111 KB
Summary

Legal correspondence from Ghislaine Maxwell's defense attorney, Jeffrey Pagliuca, to the US Attorney's Office regarding objections to hearsay statements. The defense objects to statements made by Epstein to employees (specifically CC-1) about Maxwell 'finding girls' and instructions regarding computer removal, arguing these occurred post-conspiracy and constitute 'idle chatter' rather than furtherance of a conspiracy. The letter also addresses the scope of 'minor victims' referenced in the indictment versus those in Florida investigations.

People (5)

Name Role Context
Jeffrey S. Pagliuca Defense Attorney
Author of the letter representing Ghislaine Maxwell.
Ghislaine Maxwell Defendant
Subject of the criminal case 20 Cr. 330 (AJN).
Jeffrey Epstein Deceased / Co-conspirator
Cited as making hearsay statements to employees and victims.
CC-1 Co-conspirator / Employee
Recipient of statements from Epstein regarding Maxwell finding girls; received direction to help remove computers.
CC-2 Co-conspirator
Gave direction alongside Epstein to CC-1 to help take computers; made statements to families of victims.

Organizations (2)

Name Type Context
Haddon, Morgan and Foreman, P.C
Law firm representing Ghislaine Maxwell.
United States Attorney's Office
Recipient of the letter; Southern District of New York.

Timeline (3 events)

2021-10-11
Correspondence from government to defense counsel regarding minor victims
N/A
Government Defense Counsel
2021-11-01
Court Order issued
SDNY
Court
Unknown
Direction to remove computers
Unknown

Locations (3)

Location Context
Location of Haddon, Morgan and Foreman, P.C.
Location of US Attorney's Office SDNY.
Referenced in relation to state and federal investigations involving minor victims.

Relationships (3)

Jeffrey Epstein Co-conspirators (alleged) Ghislaine Maxwell
Epstein statement that Maxwell 'used to find girls for him'.
Jeffrey Epstein Employer/Employee (implied) CC-1
Statements categorized under 'Statements made by Jeffrey Epstein to his employees'.
Jeffrey Epstein Co-conspirators CC-2
Jointly gave direction to CC-1 to help take computers.

Key Quotes (4)

"The first exemplar is a statement allegedly from Epstein to CC-1 claiming that Ms. Maxwell 'used to find girls for him.'"
Source
EFTA00014982.pdf
Quote #1
"direction from Epstein and CC-2 to CC-1 to 'help someone who was coming to take the computers....'"
Source
EFTA00014982.pdf
Quote #2
"Statements made by Epstein to friends and Family of Minor Victims"
Source
EFTA00014982.pdf
Quote #3
"Statements made by CC-2 to friends and Family of Minor Victims"
Source
EFTA00014982.pdf
Quote #4

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