DOJ-OGR-00009600.jpg
774 KB
Extraction Summary
9
People
1
Organizations
1
Locations
1
Events
6
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
774 KB
Summary
This legal document is a court filing in which the defendant argues for the case to be dismissed due to substantial prejudice caused by pre-indictment delay. The defendant claims the deaths of several witnesses, including architects, a property manager, and a housekeeper who worked for Epstein, as well as others like Jeffrey Epstein himself, prevent a fair trial. The document indicates the Court has previously rejected these arguments as speculative and lacking evidence of actual prejudice.
People (9)
| Name | Role | Context |
|---|---|---|
| Alberto Pinto | architect |
Mentioned as an unavailable witness; an architect who worked for Epstein.
|
| Roger Salhi | architect |
Mentioned as an unavailable witness; an architect who worked for Epstein.
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| Epstein |
Mentioned as the employer of unavailable witnesses Alberto Pinto, Roger Salhi, Sally Markham, and Lynn Fontanilla. Al...
|
|
| Sally Markham | property manager |
Mentioned as an unavailable witness; a property manager for Epstein's properties in the early 2000s.
|
| Lynn Fontanilla | live-in housekeeper |
Mentioned as an unavailable witness; the live-in housekeeper in Epstein's New York townhouse.
|
| Jeffrey Epstein |
Mentioned in a footnote as a potential witness who could have provided contradictory evidence.
|
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| Epstein's mother |
Mentioned in a footnote as a potential witness.
|
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| Michael Casey | alleged agent of Minor Victim-1 |
Mentioned in a footnote as a potential witness.
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| Joseph Recarey | Detective |
Mentioned in a footnote as a Palm Beach Police Department Detective and potential witness.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Palm Beach Police Department | government agency |
Mentioned in a footnote as the employer of Detective Joseph Recarey.
|
Timeline (1 events)
A defendant is arguing for dismissal of a case due to substantial prejudice from pre-indictment delay, citing the death and unavailability of several witnesses.
defendant
Locations (1)
| Location | Context |
|---|---|
|
Location of Epstein's townhouse where Lynn Fontanilla was a housekeeper.
|
Relationships (6)
Alberto Pinto was an architect who worked for Epstein.
Roger Salhi was an architect who worked for Epstein.
Sally Markham was a property manager hired to help run Epstein’s properties.
Lynn Fontanilla was the live-in housekeeper in Epstein’s New York townhouse.
The document refers to "Jeffrey Epstein, Epstein's mother".
Michael Casey is described as "the alleged agent of Minor Victim-1".
Key Quotes (5)
"[U]navailable witnesses are inherent in any delay, even if justifiable. To merit dismissal a defendant must demonstrate a substantial, actual prejudice to his ability to defend himself."Source
— United (likely a court case citation)
(A legal standard cited to argue that the unavailability of witnesses alone does not compel a finding of actual prejudice.)
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Quote #1
"already mentioned in [her] previous filings"Source
— defendant
(A quote from the defendant's motion describing a group of potential witnesses.)
DOJ-OGR-00009600.jpg
Quote #2
"could have provided evidence contradicting the government’s proof."Source
— defendant
(The defendant's assertion about what unavailable witnesses could have testified to.)
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Quote #3
"provide[d] no indication of what many of these potential witnesses might have testified to"Source
— The Court
(A previous finding by the Court regarding the defendant's claims of prejudice.)
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Quote #4
"serious doubts under all of the relevant circumstances that a jury would have found testimony from Epstein credible even if he had waived his right against self-incrimination and testified on her behalf."Source
— The Court
(A previous notation by the Court regarding the credibility of potential testimony from Jeffrey Epstein.)
DOJ-OGR-00009600.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,290 characters)
Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 38 of 51
Pierre-Louis, 2018 WL 4043140, at *4-5 (death of a defense witness and defendant’s own memory issues insufficient prejudice).
2. Discussion
The defendant contends that she has suffered substantial prejudice due to the death of certain witnesses and the unavailability of certain documentary records. (Def. Mot. at 25-30). The defendant’s speculative claims fail to establish substantial and actual prejudice caused by the allegedly excessive pre-indictment delay. See Birney, 686 F.2d at 105-06.
The defendant claims she has suffered substantial prejudice as a result of pre-indictment delay due to the unavailability of (1) Alberto Pinto and Roger Salhi, architects who worked for Epstein; (2) Sally Markham, “a property manager hired to help run Epstein’s properties in the early 2000s”; and (3) Lynn Fontanilla, the live-in housekeeper in Epstein’s New York townhouse. (Def. Mot. at 29-30).⁹ The defendant’s speculative claims of prejudice do not withstand scrutiny. First, the fact that certain deceased witnesses cannot testify does not compel a finding of actual prejudice. “[U]navailable witnesses are inherent in any delay, even if justifiable. To merit dismissal a defendant must demonstrate a substantial, actual prejudice to his ability to defend himself.” United
⁹ The defendant also reasserts that the witnesses “already mentioned in [her] previous filings”— namely, Jeffrey Epstein, Epstein’s mother, Michael Casey (the alleged agent of Minor Victim-1), and Palm Beach Police Department Detective Joseph Recarey—“could have provided evidence contradicting the government’s proof.” (Def. Mot. at 29). The Court already rejected the defendant’s claims of actual prejudice as to these witnesses, finding that the defendant “provide[d] no indication of what many of these potential witnesses might have testified to” and noting “serious doubts under all of the relevant circumstances that a jury would have found testimony from Epstein credible even if he had waived his right against self-incrimination and testified on her behalf.” (Dkt. No. 207 at 18). The defendant offers no new arguments as to these witnesses, and her claims certainly fare no better after the trial in this matter.
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DOJ-OGR-00009600
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