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Extraction Summary

6
People
4
Organizations
0
Locations
2
Events
4
Relationships
4
Quotes

Document Information

Type: Court transcript
File Size: 635 KB
Summary

This document is a page from a court transcript (United States v. Ghislaine Maxwell) dated August 10, 2022. Defense attorney Mr. Pagliuca is arguing to admit a prior document for 'impeachment by omission,' stating that the witness (Carolyn) filed a complaint and was interviewed by the FBI in 2008 regarding sexual abuse by Epstein and his employee Sarah Kellen, but notably failed to mention Ghislaine Maxwell at that time. Pagliuca argues this contradicts the government's current narrative which emphasizes Maxwell's role while downplaying Kellen's.

People (6)

Name Role Context
Jeffrey Pagliuca Defense Attorney
Identified as 'MR. PAGLIUCA', speaking to the judge regarding impeachment by omission.
Carolyn Witness
Mentioned in the header ('Carolyn - cross') and referred to as 'the witness' who claims sexual abuse.
Jeffrey Epstein Accused
Mentioned as the subject of a previous complaint filed by the witness.
Sarah Kellen Epstein Employee
Described as an employee highlighted in the witness's complaint; Pagliuca argues her role was downplayed by the gover...
Ghislaine Maxwell Defendant
Pagliuca argues she was omitted from the witness's 2008 complaint but her role is now being 'up-played' by the govern...
The Judge Judge
Addressed as 'your Honor'.

Organizations (4)

Name Type Context
FBI
Mentioned regarding an interview with the witness in 2008.
Southern District Reporters, P.C.
Court reporting agency listed in the footer.
First Circuit
Referenced as a legal jurisdiction supporting the theory of impeachment by omission.
DOJ
Department of Justice (inferred from footer DOJ-OGR).

Timeline (2 events)

2008
FBI Interview of the witness
Unknown
2022-08-10
Court hearing (Cross-examination of Carolyn)
Courtroom (Southern District)
Mr. Pagliuca Judge Carolyn

Relationships (4)

Carolyn Accuser/Accused Jeffrey Epstein
Witness claims sexually abused her; filed complaint against him.
Sarah Kellen Employee/Employer Jeffrey Epstein
Described as 'one of Epstein's employees'.
Carolyn Accuser/Accused Sarah Kellen
Complaint highlighted Sarah Kellen.
Carolyn Accuser/Accused Ghislaine Maxwell
Defense argues Carolyn omitted Maxwell from previous complaints.

Key Quotes (4)

"The entire testimony by the government here through this witness has downplayed the role of Sarah Kellen and up-played the role of Ghislaine Maxwell"
Source
DOJ-OGR-00013210.jpg
Quote #1
"in 2008, shortly after being interviewed by the FBI about the same subject matter with counsel, there is no mention of Maxwell in this entire complaint."
Source
DOJ-OGR-00013210.jpg
Quote #2
"This is a complaint against two people that this witness claims sexually abused her. It's not only against Epstein, it's against one of Epstein's employees who is highlighted in this complaint."
Source
DOJ-OGR-00013210.jpg
Quote #3
"impeachment by omission typically occurs where there is a document or a statement where the witness would likely include whatever is omitted"
Source
DOJ-OGR-00013210.jpg
Quote #4

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