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581 KB
Extraction Summary
2
People
1
Organizations
0
Locations
2
Events
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Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
581 KB
Summary
This legal document, filed on behalf of Ms. Maxwell, argues that the government's failure to disclose information about alleged coconspirators prevents a fair trial. The defense claims this failure makes it impossible to cross-examine witnesses effectively, especially since Jeffrey Epstein is deceased, and creates a risk of false testimony being introduced without challenge. This inability to confront coconspirator statements, combined with the age of the allegations, severely hampers the preparation of a defense.
People (2)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Purported coconspirator |
Mentioned as being dead and therefore unavailable to testify at trial.
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| Ms. Maxwell | Defendant |
The subject of the legal filing, arguing that the failure to disclose coconspirator statements prevents her from prep...
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| government | government agency |
Referred to as the prosecuting party whose failure to disclose information is the subject of the motion.
|
Timeline (2 events)
A trial where Ms. Maxwell is the defendant.
Ms. Maxwell's Motion to Dismiss for Pre-Indictment Delay, Dkt. 138.
Relationships (1)
The document refers to 'identified purported coconspirators' and then immediately names Jeffrey Epstein as one who is unavailable to testify because he is dead.
Key Quotes (2)
"Why did you go to the house?"Source
— Government Lawyer
(A hypothetical question posed to an accuser during trial, used as an example in the legal argument.)
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Quote #1
"Because [insert coconspirator] said that Maxwell said [insert expedient non-disclosed [statement]]."Source
— Witness/Accuser
(A hypothetical answer from a witness/accuser, illustrating how a statement from an unavailable coconspirator could be introduced to inculpate Ms. Maxwell.)
DOJ-OGR-00005601.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,601 characters)
Case 1:20-cr-00330-PAE Document 384 Filed 10/29/21 Page 7 of 12
III. The Failure to Disclose Prevents Defense Cross Examination at Trial and Facilitates the Presentation of False Testimony
None of the identified purported coconspirators are available to testify at trial. Jeffrey Epstein is dead, and neither [REDACTED] have been granted immunity for their trial testimony. Accordingly, Ms. Maxwell cannot cross-examine any identified coconspirator about whether he or she made any yet-to-be attributed statement. The government’s failure to disclose creates a real danger that during trial one or more of the alleged accusers will, for the first time, offer some alleged 801(d)(2)(E) statement attempting to inculpate Ms. Maxwell. Thus, it is entirely possible that any one of the accusers could be asked, for example,
Government Lawyer: Why did you go to the house?
Witness/Accuser: Because [insert coconspirator] said that Maxwell said [insert expedient non-disclosed [statement]].
This is an invitation to manufacture evidence which Ms. Maxwell cannot cross examine.
In addition, the failure to disclose implicates many of the issues raised in Ms. Maxwell’s previously filed motions. The allegations are decades old, and Ms. Maxwell raised concerns about lack of memory and available witnesses in her Motion to Dismiss for Pre-Indictment Delay, Dkt. 138. It has been difficult to track down and interview relevant percipient witnesses to the alleged events. The failure of disclosure of critical alleged coconspirator statements makes it impossible to prepare a defense.
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DOJ-OGR-00005601
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