DOJ-OGR-00009602.jpg
715 KB
Extraction Summary
10
People
1
Organizations
1
Locations
1
Events
6
Relationships
6
Quotes
Document Information
Type:
Legal document
File Size:
715 KB
Summary
This legal document is a court filing arguing against a defendant's claim of prejudice due to the unavailability of certain witnesses. The filing contends that the defendant has failed to prove these witnesses (architects Pinto and Salhi) were 'key' or that their testimony would have been irreplaceably helpful. It further points out that the defendant had the opportunity to, and did, cross-examine other employees of Epstein, such as Juan Alessi and pilots Larry Visoski and David Rodgers, to establish facts about the defendant's role and time spent at Epstein's residences.
People (10)
| Name | Role | Context |
|---|---|---|
| Epstein | Employer |
Mentioned as the employer of the defendant and several witnesses. The document discusses witnesses' time with him and...
|
| Pierre-Louis |
Cited in a legal case reference (Pierre-Louis, 2018 WL 4043140, at *4).
|
|
| Spears |
Cited in a legal case reference (Spears, 159 F.3d at 1081–85).
|
|
| Cornielle |
Cited in a legal case reference (Cornielle, 171 F.3d at 752).
|
|
| Pinto | Architect |
Cited by the defendant as an absent witness, described as an architect who worked on Epstein's residences.
|
| Salhi | Architect |
Cited by the defendant as an absent witness, described as an architect who worked on Epstein's residences.
|
| Jane | Witness/Victim |
Mentioned in the context of the defendant speculating that testimony from Pinto and Salhi would have cast doubt on he...
|
| Juan Alessi | Employee |
Mentioned as an employee of Epstein who was cross-examined at trial by the defendant.
|
| Larry Visoski | Pilot |
Mentioned as a pilot for Epstein who was cross-examined at trial by the defendant.
|
| David Rodgers | Pilot |
Mentioned as a pilot for Epstein who was cross-examined at trial by the defendant.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| DOJ | government agency |
Appears in the footer as part of a document control number (DOJ-OGR-00009602).
|
Timeline (1 events)
The defendant's trial, during which other employees of Epstein were cross-examined.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned as places where employees worked and where architects Pinto and Salhi built, renovated, and decorated.
|
Relationships (6)
The document states that other employees who worked for Epstein and the defendant were available to offer testimony, implying a co-working or employer-employee relationship.
Pinto is described as an 'architect who built, renovated, and decorated many of Epstein’s residences'.
Salhi is described as an 'architect who built, renovated, and decorated many of Epstein’s residences'.
Described as one of the 'other employees who worked for Epstein'.
Described as one of Epstein's 'pilots'.
Described as one of Epstein's 'pilots'.
Key Quotes (6)
"every moment"Source
— unspecified
(Describing that witnesses were not with the defendant and Epstein at all times during the period in the Indictment.)
DOJ-OGR-00009602.jpg
Quote #1
"impossible"Source
— Pierre-Louis, 2018 WL 4043140, at *4
(Quoted to argue it would be impossible for the witnesses to testify that the defendant did not commit the crimes.)
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Quote #2
"to testify that [the] defendant did not commit the charged crimes, so whatever helpful testimony [they] might have offered (the details of which are sparse in the motion) would be easily undermined on cross-examination."Source
— Pierre-Louis, 2018 WL 4043140, at *4
(Explaining why the testimony of certain witnesses would be of limited value and easily challenged.)
DOJ-OGR-00009602.jpg
Quote #3
"key"Source
— unspecified
(Used to describe the type of witnesses the defendant has failed to establish the four individuals were.)
DOJ-OGR-00009602.jpg
Quote #4
"architects who built, renovated, and decorated many of Epstein’s residences"Source
— unnamed defendant
(The defendant's description of absent witnesses Pinto and Salhi.)
DOJ-OGR-00009602.jpg
Quote #5
"would have cast significant doubt on Jane’s recollection of events."Source
— unnamed defendant
(The defendant's speculation on the impact of Pinto and Salhi's potential testimony.)
DOJ-OGR-00009602.jpg
Quote #6
Full Extracted Text
Complete text extracted from the document (2,103 characters)
Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 40 of 51
fact, participate in the sexual abuse of the victims in the manner described in the Indictment. As a factual matter, the record is crystal clear that these witnesses were not with the defendant and Epstein at “every moment” during the period charged in the Indictment. See Pierre-Louis, 2018 WL 4043140, at *4. It would thus be “impossible” for them “to testify that [the] defendant did not commit the charged crimes, so whatever helpful testimony [they] might have offered (the details of which are sparse in the motion) would be easily undermined on cross-examination.” Id. (citing Spears, 159 F.3d at 1081–85). Moreover, even assuming that these witnesses would have testified as the defendant claims and that such testimony would have been admissible, the defendant does not address why the unavailability of these particular individuals has caused her actual prejudice when other employees who worked for Epstein and the defendant were available to offer (and did offer) testimony about Epstein’s residences and the defendant’s role and time spent at such residences. It is the defendant’s burden to establish that these witnesses’ testimony could not be put before the jury through other means, and the defendant has not established—and cannot establish—that these four witnesses were “key” witnesses who would have testified at her trial in an irreplaceable way that would have helped, rather than hurt, her. Cornielle, 171 F.3d at 752.
In particular, the defendant cites the absence of Pinto and Salhi, “architects who built, renovated, and decorated many of Epstein’s residences” and speculates that their testimony “would have cast significant doubt on Jane’s recollection of events.” (Def. Mot. at 29). The defendant has not set forth what Pinto and Salhi would have attested to had the charges been brought sooner. Moreover, at trial, the defendant cross-examined other employees who worked for Epstein during the relevant time periods—such as Juan Alessi and pilots Larry Visoski and David Rodgers—and
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DOJ-OGR-00009602
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