DOJ-OGR-00002914.jpg
803 KB
Extraction Summary
3
People
3
Organizations
2
Locations
7
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
803 KB
Summary
This legal document, filed on April 9, 2021, details the Government's investigative actions concerning "Minor Victim-4" and the "defendant." It outlines a series of interviews with Minor Victim-4, conducted via video and in-person between summer 2020 and January 2021, alongside further investigative steps. The document asserts that a superseding indictment (S2 Indictment) was timely presented to a grand jury in late March, refuting the defense's claims of intentional delay or that the indictment acknowledges the strength of pretrial motions.
People (3)
| Name | Role | Context |
|---|---|---|
| Minor Victim-4 | Victim (implied) |
Did not agree to be interviewed by the Government until July 2020; subject of preliminary interviews by video telecon...
|
| defendant | Defendant |
Will be able to confirm for herself upon receipt of Jencks Act material; party against whom the S2 Indictment was bro...
|
| additional witnesses | Witnesses |
Interviewed by the Government as part of additional investigation to corroborate Minor Victim-4.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Conducted the Florida Investigation; sought to interview Minor Victim-4; conducted preliminary and in-person intervie...
|
| grand jury | government agency |
Received the superseding indictment (S2 Indictment) from the Government in late March.
|
| defense | legal entity/party |
Received documents in discovery; made suggestions regarding the S2 Indictment; made pretrial motions.
|
Timeline (7 events)
2020-06-01
Government conducted two preliminary interviews with Minor Victim-4 by video teleconference.
2020-07-01
Minor Victim-4 did not agree to be interviewed by the Government.
2021-01-01
Government was unable to travel to meet with Minor Victim-4 due to travel constraints and COVID-19 pandemic.
New York (Minor Victim-4's residence)
2021-01-31
Government conducted multiple in-person interviews with Minor Victim-4, concluding near the end of January 2021.
2021-03-31
Government conducted additional investigation to corroborate Minor Victim-4, including interviewing additional witnesses, reviewing documents, and subpoenaing additional records.
2021-03-31
Government completed internal processes to prepare a superseding indictment (S2 Indictment) and presented it to the grand jury.
Relationships (3)
The Government conducted interviews and investigations concerning Minor Victim-4 to corroborate information for a legal case.
The Government is prosecuting the defendant, and the document addresses the defense's arguments regarding the S2 Indictment.
Minor Victim-4 is a victim in a case where the defendant is being prosecuted, and the Government's investigation relates to corroborating Minor Victim-4's account.
Full Extracted Text
Complete text extracted from the document (2,398 characters)
Case 1:20-cr-00330-PAE Document 199 Filed 04/09/21 Page 2 of 8
Page 2
Page 2
or about 2007 during the Florida Investigation, as the defendant will be able to confirm for herself upon receipt of Jencks Act material, Minor Victim-4 did not agree to be interviewed by the Government until July 2020. The Government then conducted two preliminary interviews with Minor Victim-4 by video teleconference in the summer of 2020. Because of the difficult nature of the interview topics, however, the Government was not able to fully debrief Minor Victim-4 over video. Due to travel constraints and safety concerns arising from the COVID-19 pandemic, the Government was unable to travel to meet with Minor Victim-4, who resides more than a day's drive away from New York, until January 2021. The Government then conducted multiple in-person interviews with Minor Victim-4, which concluded near the end of January 2021. Over the next two months, the Government worked expeditiously to conduct additional investigation to corroborate Minor Victim-4, including by interviewing additional witnesses, reviewing documents that had already been produced to the defense in discovery, and subpoenaing additional records, which the Government promptly produced to the defense upon receipt. After taking those investigative steps, the Government completed the necessary internal processes to prepare a superseding indictment, which it presented to the grand jury in late March, or approximately two months after concluding its debriefing of Minor Victim-4.
Simply put, the S2 Indictment was brought in a timely manner upon the Government's collection of evidence to support the additional charges. The suggestion that the Government intentionally delayed obtaining the S2 Indictment to gain some strategic advantage has no basis in fact. Nor is there any merit to the defense's equally baseless suggestions that the Government
¹ The defense's implication that the S2 Indictment somehow reflects an acknowledgment of the strength of the defense's pretrial motions is similarly baseless and entirely illogical. Were that the case, and if the Government could have (as the defense incorrectly speculates) obtained this indictment any time it wished, then it would make far more sense for the Government to obtain the S2 Indictment in the first place or, at bare minimum, immediately upon receiving the defense
DOJ-OGR-00002914
DOJ-OGR-00002914
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