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574 KB
Extraction Summary
7
People
3
Organizations
1
Locations
1
Events
1
Relationships
9
Quotes
Document Information
Type:
Legal document
File Size:
574 KB
Summary
This legal document, filed on January 25, 2021, argues that the indictment against Ms. Maxwell lacks sufficient specificity regarding the alleged crimes and the identities of accusers/victims. It contends that the open-ended time periods and vague descriptions of 'minor girls' or 'victims' in the indictment make it impossible for Ms. Maxwell to prepare an adequate defense or apply the statute of limitations. The document cites legal precedents to support the argument for greater specificity in criminal charges.
People (7)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
The Indictment and discovery do not inform her about critical information necessary to prepare her defense.
|
| Jain | Party in a cited legal case |
Cited in United States v. Jain, No. 19-CR-59 (PKC).
|
| Resendiz-Ponce | Party in a cited legal case |
Cited in United States v. Resendiz-Ponce, 549 U.S. 102.
|
| individuals accusing Ms. Maxwell | Accusers |
Not identified in the Indictment, making it difficult for Ms. Maxwell to prepare a defense.
|
| minor girls | Alleged victims |
Phrase used in the Indictment, criticized for vagueness.
|
| victims | Alleged victims |
Phrase used in the Indictment, criticized for vagueness, some described as young as 14.
|
| certain girls | Alleged victims |
Phrase used in the Indictment, described as being under the age of 18.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States | Government |
Party in cited legal cases (United States v. Jain, United States v. Resendiz-Ponce).
|
| S.D.N.Y. | Court |
Southern District of New York, context for a cited legal precedent.
|
| Government | Government agency |
The entity claiming certain individuals are 'victims' in the Indictment against Ms. Maxwell.
|
Timeline (1 events)
2021-01-25
Document 124 filed in Case 1:20-cr-00330-AJN, arguing against the sufficiency and specificity of an indictment.
Locations (1)
| Location | Context |
|---|---|
|
Southern District of New York, mentioned in a legal citation.
|
Relationships (1)
The document discusses the Indictment against Ms. Maxwell and the Government's claims, indicating a legal dispute.
Key Quotes (9)
"When supplemented by discovery material, no additional information is necessary for trial preparation or to prevent surprise."Source
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Quote #1
"while an indictment parroting the language of a federal criminal statute is often sufficient, there are crimes that must be charged with greater specificity."Source
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Quote #2
"from at least in or about 1994, up to and including at least in or about 1997"Source
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Quote #3
"beginning in at least 1994"Source
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Quote #4
"victim"Source
— Government
(Refers to how the Government characterizes certain individuals in the Indictment.)
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Quote #5
"minor girls"Source
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Quote #6
"victims"Source
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Quote #7
"victims were as young as 14"Source
DOJ-OGR-00002315.jpg
Quote #8
"certain girls were in fact under the age of 18"Source
DOJ-OGR-00002315.jpg
Quote #9
Full Extracted Text
Complete text extracted from the document (1,613 characters)
Case 1:20-cr-00330-AJN Document 124 Filed 01/25/21 Page 5 of 8
In many cases the bar for sufficiency of an indictment is low. It is also true that courts
find, in certain cases, that the discovery provided in connection with the matter may cure various
pleading deficiencies. See, e.g., United States v. Jain, No. 19-CR-59 (PKC), 2019 WL 6888635,
at *2 (S.D.N.Y. Dec. 18, 2019) (“When supplemented by discovery material, no additional
information is necessary for trial preparation or to prevent surprise.”). However, “while an
indictment parroting the language of a federal criminal statute is often sufficient, there are crimes
that must be charged with greater specificity.” United States v. Resendiz-Ponce, 549 U.S. 102 at
109.
find, in certain cases, that the discovery provided in connection with the matter may cure various
pleading deficiencies. See, e.g., United States v. Jain, No. 19-CR-59 (PKC), 2019 WL 6888635,
at *2 (S.D.N.Y. Dec. 18, 2019) (“When supplemented by discovery material, no additional
information is necessary for trial preparation or to prevent surprise.”). However, “while an
indictment parroting the language of a federal criminal statute is often sufficient, there are crimes
that must be charged with greater specificity.” United States v. Resendiz-Ponce, 549 U.S. 102 at
109.
These are those crimes.
Here, neither the Indictment nor the discovery inform Ms. Maxwell about critical
information necessary to prepare her defense. The Indictment contains multiple open-ended time
periods:
• “from at least in or about 1994, up to and including at least in or about 1997”
¶¶ 1, 9, 13, 15; and
• “beginning in at least 1994” ¶ 4.
These phrases make the time frame alleged limitless and meaningless for application of
the statute of limitations or any defense.
In addition to not identifying the individuals accusing Ms. Maxwell of a crime, the
Indictment, through the use of inconsistent and vague phrases, makes it impossible to know who
may, or may not, be someone that the Government claims is a “victim.”
• “minor girls” ¶ 1;
• “victims” ¶ 1;
• “victims were as young as 14” ¶ 1;
• “certain girls were in fact under the age of 18” ¶ 1;
information necessary to prepare her defense. The Indictment contains multiple open-ended time
periods:
• “from at least in or about 1994, up to and including at least in or about 1997”
¶¶ 1, 9, 13, 15; and
• “beginning in at least 1994” ¶ 4.
These phrases make the time frame alleged limitless and meaningless for application of
the statute of limitations or any defense.
In addition to not identifying the individuals accusing Ms. Maxwell of a crime, the
Indictment, through the use of inconsistent and vague phrases, makes it impossible to know who
may, or may not, be someone that the Government claims is a “victim.”
• “minor girls” ¶ 1;
• “victims” ¶ 1;
• “victims were as young as 14” ¶ 1;
• “certain girls were in fact under the age of 18” ¶ 1;
2
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