DOJ-OGR-00003089.jpg
753 KB
Extraction Summary
6
People
2
Organizations
3
Locations
2
Events
3
Relationships
7
Quotes
Document Information
Type:
Legal document
File Size:
753 KB
Summary
This legal document, part of case 1:20-cr-00330-PAE filed on April 16, 2021, presents an argument that a jury could find the defendant's testimony to be false. The prosecution argues that the defendant, likely Maxwell, falsely claimed to be unaware of any minors at Jeffrey Epstein's properties besides Giuffre, contradicting an indictment alleging interactions with 'Minor Victim-1'. The document refutes the defense's claims that the questions were ambiguous or improper, citing the defendant's own statements that the events in question 'never happened'.
People (6)
| Name | Role | Context |
|---|---|---|
| Epstein |
Mentioned in relation to his various properties, residences, and house where interactions with the defendant and othe...
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|
| MAXWELL |
Quoted from an indictment as having interacted with Minor Victim-1. Likely the defendant in the case.
|
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| Minor Victim-1 | Victim |
Mentioned in an indictment as having interacted with MAXWELL at Epstein's residences.
|
| Jeffrey Epstein |
Full name mentioned in the context of his properties.
|
|
| Giuffre |
Mentioned as the only minor the defendant claimed to be aware of.
|
|
| Olivieri |
Mentioned in a case citation (Forde, 740 F. Supp. 2d at 413).
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Mentioned as a party in the legal proceedings, noting the defendant's response to an earlier question.
|
| DOJ-OGR | government agency |
Appears in the footer as part of a document identifier (DOJ-OGR-00003089).
|
Timeline (2 events)
MAXWELL subsequently interacted with Minor Victim-1 on multiple occasions at Epstein’s residences.
Epstein’s residences
The defendant was questioned about minors she interacted with at Jeffrey Epstein's properties and gave answers that are now being challenged as false.
defendant
Locations (3)
| Location | Context |
|---|---|
|
Location where interactions between the defendant and Epstein occurred.
|
|
|
Location where MAXWELL allegedly interacted with Minor Victim-1.
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Location where the defendant was asked if she had 'met and brought' underage girls.
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Relationships (3)
The document describes interactions between the defendant and Epstein at his various properties.
An indictment alleges that MAXWELL interacted with Minor Victim-1 on multiple occasions at Epstein's residences.
The defendant answered that she was aware of no minors other than Giuffre at Epstein's properties.
Key Quotes (7)
"MAXWELL subsequently interacted with Minor Victim-1 on multiple occasions at Epstein’s residences."Source
— Indictment
(Quoted from an indictment (¶ 7(a)) to show evidence of the defendant's interactions with minors.)
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Quote #1
"with a meaning about which [people] of ordinary intellect could agree,"Source
— Lighte, 782 F.2d at 375
(A legal standard cited to argue that the terms in the question posed to the defendant were not fundamentally ambiguous.)
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Quote #2
"met and brought"Source
— Unknown questioner
(Part of an earlier question to the defendant asking her to list underage girls she 'met and brought' to Epstein's house.)
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Quote #3
"improper"Source
— defendant
(The defendant's argument that the charged question was improper.)
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Quote #4
"from events that had happened nearly two decades previously."Source
— defendant
(The defendant's reason for arguing the question was improper, as it asked her to generate a list from distant events.)
DOJ-OGR-00003089.jpg
Quote #5
"because that list -- it never happened that I can think of."Source
— defendant
(The defendant's stated reason for not being able to make a list of underage girls, implying such events never occurred.)
DOJ-OGR-00003089.jpg
Quote #6
"was not aware of anybody"Source
— defendant
(The defendant's response to the charged question about minors under 18.)
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Quote #7
Full Extracted Text
Complete text extracted from the document (2,262 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 155 of 239
interactions with the defendant and Epstein at Epstein’s various properties. See, e.g., Indictment
¶ 7(a) (“MAXWELL subsequently interacted with Minor Victim-1 on multiple occasions at
Epstein’s residences.”). Accordingly, a rational juror, after hearing the evidence, could find that
the question called for the names of minors that the defendant interacted with at any of Jeffrey
Epstein’s properties, that the defendant answered that she was aware of no such minors other than
Giuffre, and therefore that her answer was false. And even if the defendant identifies some
plausible ambiguity—and she has not—the terms in this question are ones “with a meaning about
which [people] of ordinary intellect could agree,” and therefore are not fundamentally ambiguous.
Lighte, 782 F.2d at 375 (internal quotation marks omitted).
The defendant points out that, in response to an earlier question asking her to list the
underage girls she “met and brought” to Epstein’s house, she said that she could not do so. (Def.
Mot. 4 at 12-13). She argues that the charged question was “improper” because it asked her to
generate a list “from events that had happened nearly two decades previously.” (Id.). Her
unpersuasive after-the-fact efforts to justify her answer provide no basis to keep this question from
the jury. As noted above, the transcript makes clear (and a jury could find) that when the defendant
did not understand or could not answer a question, she said so. To the extent the defendant is
arguing that her answer was literally true, a reasonable jury could find otherwise. In this respect,
the Government notes, among other things, that in response to the earlier question, the defendant
said that she could not make a list not because she could not remember events from that long ago
but “because that list -- it never happened that I can think of.” (Ex. 10 at 382:4-13) (emphasis
added). And in response to the charged question, the defendant said that she “was not aware of
anybody” under 18—that is, the list would be empty. See Forde, 740 F. Supp. 2d at 413 (“Olivieri,
if truly confused, could also have asked for clarification. Instead he replied with a strong
¶ 7(a) (“MAXWELL subsequently interacted with Minor Victim-1 on multiple occasions at
Epstein’s residences.”). Accordingly, a rational juror, after hearing the evidence, could find that
the question called for the names of minors that the defendant interacted with at any of Jeffrey
Epstein’s properties, that the defendant answered that she was aware of no such minors other than
Giuffre, and therefore that her answer was false. And even if the defendant identifies some
plausible ambiguity—and she has not—the terms in this question are ones “with a meaning about
which [people] of ordinary intellect could agree,” and therefore are not fundamentally ambiguous.
Lighte, 782 F.2d at 375 (internal quotation marks omitted).
The defendant points out that, in response to an earlier question asking her to list the
underage girls she “met and brought” to Epstein’s house, she said that she could not do so. (Def.
Mot. 4 at 12-13). She argues that the charged question was “improper” because it asked her to
generate a list “from events that had happened nearly two decades previously.” (Id.). Her
unpersuasive after-the-fact efforts to justify her answer provide no basis to keep this question from
the jury. As noted above, the transcript makes clear (and a jury could find) that when the defendant
did not understand or could not answer a question, she said so. To the extent the defendant is
arguing that her answer was literally true, a reasonable jury could find otherwise. In this respect,
the Government notes, among other things, that in response to the earlier question, the defendant
said that she could not make a list not because she could not remember events from that long ago
but “because that list -- it never happened that I can think of.” (Ex. 10 at 382:4-13) (emphasis
added). And in response to the charged question, the defendant said that she “was not aware of
anybody” under 18—that is, the list would be empty. See Forde, 740 F. Supp. 2d at 413 (“Olivieri,
if truly confused, could also have asked for clarification. Instead he replied with a strong
128
DOJ-OGR-00003089
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