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716 KB
Extraction Summary
5
People
2
Organizations
0
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
716 KB
Summary
This legal document is a page from a court filing, dated April 16, 2021, concerning a defendant's motion to dismiss two counts of perjury. The charges stem from depositions in April and July 2016, where the defendant was ordered to answer questions about her involvement with Epstein and Giuffre in a prior defamation case. The document outlines the court's previous orders and introduces the applicable law for perjury, citing legal standards for determining if a statement is knowingly false.
People (5)
| Name | Role | Context |
|---|---|---|
| Epstein |
Mentioned as a subject of questions the defendant was ordered to answer regarding her sexual activity and knowledge.
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| Giuffre |
Mentioned as a subject of questions the defendant was ordered to answer regarding her sexual activity.
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| Defendant | Defendant |
The subject of the legal filing, who was ordered to answer questions in depositions and is now charged with perjury a...
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| Plaintiff | Plaintiff |
The opposing party in the original defamation claim mentioned in the document.
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| Lighte |
Named in the case citation 'United States v. Lighte', which is used to establish a legal standard for perjury prosecu...
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| Court | Government agency |
Referenced throughout as the judicial body that ordered the defendant to answer questions and is now considering a mo...
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| 2d Cir. | Government agency |
Referenced in a case citation (2d Cir. 1986), indicating the United States Court of Appeals for the Second Circuit.
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Relationships (2)
The Court ordered the defendant to answer questions about her sexual activity with or involving Epstein, and her knowledge of underage girls known to Epstein.
Key Quotes (4)
"That knowledge... goes directly to the truth or falsity of the alleged defamation, a key element of Plaintiff’s claim."Source
— The Court
(The Court's explanation for why the defendant's knowledge was relevant to the original defamation case.)
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Quote #1
"scope of Defendant’s answers are not bound by time period, though Defendant need not answer questions that relate to none of these subjects or that is clearly not relevant."Source
— The Court
(The Court's instruction regarding the breadth of the defendant's required testimony.)
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Quote #2
"in any proceeding before or ancillary to any court . . . knowingly makes any false material declaration."Source
— Section 1623(a)
(A quote from the U.S. Code defining the crime of making a false declaration in a court proceeding.)
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Quote #3
"whether the witness believes that an answer is true or false generally turns on the declarant’s understanding of the question."Source
— United States v. Lighte
(A legal standard cited from a previous case to define how truthfulness is assessed in perjury prosecutions.)
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,131 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 146 of 239
(Def. Mot. 4, Ex. H at 9). “That knowledge,” the Court explained, “goes directly to the truth or falsity of the alleged defamation, a key element of Plaintiff’s claim.” (Id.). The Court therefore ordered the defendant to answer the questions related to her sexual activity with or involving (1) Epstein, (2) Giuffre, (3) underage girls known to Epstein or who she thought might become known to Epstein, or (4) involving massage with individuals the defendant “knew to be, or believed might be, known to Epstein.” (Id. at 10). The Court further ordered the defendant to answer questions about her knowledge of the sexual activities of others in the same four categories. The Court added that the “scope of Defendant’s answers are not bound by time period, though Defendant need not answer questions that relate to none of these subjects or that is clearly not relevant.” (Id.). The defendant sat for a second deposition on July 22, 2016, before the case settled.
As discussed more fully below, the Indictment charges the defendant with two counts of perjury, one arising from statements made during the April 2016 deposition and one arising from statements made during the July 2016 deposition. Indictment ¶¶ 21, 23. (Ex. 10 at 253:25-254:8, 384:15-20; Ex. 11 at 88:9-89:13, 91:22-92:16, 113:2-12). The defendant now moves to dismiss both counts, arguing that the Court can effectively decide now, as a matter of law, that the questions were fundamentally ambiguous, her answers were true, and her answers were immaterial to the case.
B. Applicable Law
Section 1623(a) imposes criminal penalties on anyone who “in any proceeding before or ancillary to any court . . . knowingly makes any false material declaration.” 18 U.S.C. § 1623(a). In perjury prosecutions, “whether the witness believes that an answer is true or false generally turns on the declarant’s understanding of the question.” United States v. Lighte, 782 F.2d 367, 372 (2d Cir. 1986). Accordingly, and as is true of virtually all factual issues, “[a] jury is best equipped
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