DOJ-OGR-00008223.jpg
535 KB
Extraction Summary
4
People
3
Organizations
6
Locations
2
Events
1
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
535 KB
Summary
This is a letter from the U.S. Department of Justice to Judge Alison J. Nathan regarding the case against Ghislaine Maxwell, dated December 5, 2021. The prosecution outlines its plan to question 'Witness-3' about sexual activity with Epstein, adhering to the court's order to avoid explicit details. The government expresses concern that this limited questioning could be misinterpreted by the jury as a lack of witness credibility, especially in light of the defense's opening argument.
People (4)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge, United States District Court |
Recipient of the letter, addressed as "The Honorable Alison J. Nathan" and "Dear Judge Nathan".
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| Ghislaine Maxwell | Defendant |
Named as the defendant in the case "United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)".
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| Witness-3 | Witness |
The subject of the letter, regarding their upcoming testimony about sexual activity with Epstein.
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| Epstein |
Mentioned as the individual who initiated sexual activity with Witness-3.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice | government agency |
The agency sending the letter.
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| United States Attorney, Southern District of New York | government agency |
The specific office within the Department of Justice that sent the letter.
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| United States District Court, Southern District of New York | government agency |
The court where Judge Nathan presides and where the case is being heard.
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Timeline (2 events)
2021-11-29
The defense opening argument in the case of United States v. Ghislaine Maxwell.
United States District Court, Southern District of New York
Ghislaine Maxwell's defense team
Locations (6)
| Location | Context |
|---|---|
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The jurisdiction of the United States Attorney and the United States District Court mentioned in the document.
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Part of the address for the United States Attorney's office.
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The address of the United States Attorney's office.
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The location of the United States District Court.
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The address of the United States Courthouse.
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The city where the US Attorney's office and the Courthouse are located.
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Key Quotes (1)
"they are going to recount things that they claim happened to them decades and decades ago. They are not going to be able to pinpoint dates . . ."Source
— defense
(Quoted from the defense's opening argument on 11/29/21, used by the Government to illustrate its concern that a lack of detail in testimony could be perceived as a lack of credibility.)
DOJ-OGR-00008223.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (1,389 characters)
Case 1:20-cr-00330-PAE Document 524 Filed 12/05/21 Page 1 of 2
U.S. Department of Justice
United States Attorney
Southern District of New York
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
One Saint Andrew’s Plaza
New York, New York 10007
December 5, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter regarding the Court’s instruction in advance of the testimony of Witness-3. Consistent with the Court’s order, the Government is planning to elicit from Witness-3 only basic information about sexual activity that occurred with Epstein (e.g., that it occurred, that Epstein initiated it, that it happened in the context of a massage, and the locations of the sexualized massages), without eliciting any details. The Government is concerned, however, that asking leading questions and obviously avoiding the details of the sexual activity will cause the jury to infer that the lack of detail reflects a lack of credibility. See, e.g., 11/29/21 Tr. at 54 (defense opening argument that “they are going to recount things that they claim happened to them decades and decades ago. They are not going to be able to pinpoint dates . . .”).
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DOJ-OGR-00008223
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