DOJ-OGR-00002962.jpg

611 KB

Extraction Summary

3
People
5
Organizations
2
Locations
2
Events
2
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 611 KB
Summary

This document is a preliminary statement from the U.S. Government in the criminal case against Ghislaine Maxwell, filed on April 16, 2021. The Government submits this memorandum to oppose twelve pre-trial motions filed by the defendant on January 25, 2021. The statement outlines the Government's arguments for denying the motions, asserting that they lack support in fact or law and addressing specific points such as the irrelevance of Jeffrey Epstein's non-prosecution agreement and the timeliness of the indictment.

People (3)

Name Role Context
GHISLAINE MAXWELL Defendant
Named as the defendant in the case UNITED STATES OF AMERICA -v.- GHISLAINE MAXWELL.
Jeffrey Epstein
Mentioned in relation to a non-prosecution agreement with the U.S. Attorney’s Office for the Southern District of Flo...
AJN Judge (initials)
Appears in the case number S1 20 Cr. 330 (AJN), likely referring to the presiding judge.

Organizations (5)

Name Type Context
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK government agency
The court where the legal document was filed.
UNITED STATES OF AMERICA government agency
The plaintiff in the case, referred to as "The Government".
U.S. Attorney’s Office for the Southern District of Florida government agency
Mentioned as having a non-prosecution agreement with Jeffrey Epstein.
Congress government agency
Mentioned in relation to the intent behind a statute of limitations.
The Government government agency
Refers to the prosecution (United States of America) throughout the document.

Timeline (2 events)

2021-01-25
The defendant, Ghislaine Maxwell, filed twelve pre-trial motions, referred to as the "Defense Motions".
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
Ghislaine Maxwell
2021-04-16
The Government submitted a memorandum in opposition to the defendant's twelve pre-trial motions.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

Locations (2)

Location Context
The location of the United States District Court handling the case.
The location of the U.S. Attorney's Office that had a non-prosecution agreement with Jeffrey Epstein.

Relationships (2)

Ghislaine Maxwell is the Defendant in a criminal case brought by the United States of America (the plaintiff/Government).
The document states there was a non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney’s Office for the Southern District of Florida.

Full Extracted Text

Complete text extracted from the document (1,840 characters)

Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 28 of 239
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------x
UNITED STATES OF AMERICA
-v.- : S1 20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
:
Defendant.
--------------------------------------------------x
PRELIMINARY STATEMENT
The Government respectfully submits this memorandum in opposition to the defendant’s
twelve pre-trial motions, dated January 25, 2021 (the “Defense Motions”). In her pretrial motions,
the defendant seeks to throw everything but the proverbial kitchen sink at the Indictment, raising
myriad arguments that find little support in fact or law. For the reasons that follow, the motions
should be denied in their entirety.
First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney’s
Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant’s
motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C. § 3283, which
provides an extended statute of limitations for crimes involving the sexual abuse of minors. The
defendant’s statute of limitations arguments run contrary to the text of the statute, the intent of
Congress, and the weight of authority. Third, the defendant’s claim that the Government delayed
in bringing the indictment fails as a matter of law and fact. Fourth, both of the defendant’s motions
to suppress evidence obtained through a judicially approved subpoena are meritless, and her
allegations of Government misconduct are baseless. Fifth, Counts Five and Six—which charge
the defendant with committing perjury—are properly pleaded, and the defendant’s motion to
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DOJ-OGR-00002962

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