DOJ-OGR-00003098.jpg
810 KB
Extraction Summary
6
People
2
Organizations
1
Locations
3
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
810 KB
Summary
This legal document is a filing arguing against a defendant's motion to dismiss a perjury charge. The prosecution contends that the defendant's false statements in a deposition for the 'Giuffre v. Maxwell' civil suit were material, as truthful answers could have corroborated claims that the defendant and Epstein recruited Giuffre and could have led to other victims or witnesses. The filing asserts that the issue of materiality is a question for the jury and should not be decided by the court at this stage.
People (6)
| Name | Role | Context |
|---|---|---|
| Giuffre | Plaintiff |
Mentioned as the plaintiff in a civil suit against Maxwell, and as the person allegedly recruited by the defendant to...
|
| Epstein |
Mentioned as the person to whom the defendant recruited Giuffre. Alleged to have had a scheme to recruit underaged gi...
|
|
| Maxwell | Defendant |
Mentioned as the defendant in the civil suit "Giuffre v. Maxwell".
|
| Judge Preska | Judge |
Mentioned in a footnote regarding her opinion on redactions in a civil case and the civil unsealing litigation.
|
| Judge Sweet | Judge |
Mentioned in a footnote as having authorized a deposition at the outset of a case.
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| Minor Victim-2 | Victim |
Mentioned in a footnote as a person whose name was redacted in an unsealed colloquy.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Court | Judicial body |
Referred to as the body that should deny the motion to dismiss and that should not resolve the question of materialit...
|
| Government | Government agency |
Mentioned in footnotes as a party to the current criminal perjury case, and as being open to crafting a stipulation r...
|
Timeline (3 events)
A deposition in the civil suit where the defendant allegedly gave perjurious statements.
defendant
Locations (1)
| Location | Context |
|---|---|
|
Location of Epstein's property where Giuffre was allegedly recruited.
|
Relationships (3)
Maxwell is the defendant in the civil suit "Giuffre v. Maxwell." The document alleges that the defendant (Maxwell) recruited Giuffre for Epstein.
The document states that the defendant recruited Giuffre to Epstein's property, implying a collaborative relationship.
Full Extracted Text
Complete text extracted from the document (2,512 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 164 of 239
statements at the heart of that case and the evidence that might have been uncovered had the defendant answered the questions truthfully. A jury should be allowed to hear the questions in context to evaluate their materiality, which cannot be done at this stage.51 The Court therefore should deny the motion.
In any event, the perjurious statements were material in both senses of the definition. First, the questions were aimed at developing a record in the civil suit that Epstein and the defendant recruited Giuffre to Epstein’s Palm Beach property in the guise of hiring her as a masseuse, and then sexualized that massage. Honest answers to those questions—for instance that Epstein in fact had a scheme to recruit underaged girls for sexual massages—would have been corroborative of some of Giuffre’s claims. Second, had the defendant honestly answered the deposition questions, Giuffre could have located other victims or witnesses who may have corroborated her testimony. But in any event, the question of materiality should be put to the jury and is inappropriate for the Court to resolve on a motion to dismiss without the benefit of the full factual record. The motion should be denied.
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allegations that were central to the dispute in Giuffre v. Maxwell.” (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2’s name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).) Yet Judge Preska’s opinion as to the propriety of certain redactions in a civil case is not controlling as to whether the Government can meet the elements of a criminal perjury charge here. First, before Judge Preska were the defendant’s denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity to be heard on this issue before Judge Preska.
allegations that were central to the dispute in Giuffre v. Maxwell.” (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2’s name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).) Yet Judge Preska’s opinion as to the propriety of certain redactions in a civil case is not controlling as to whether the Government can meet the elements of a criminal perjury charge here. First, before Judge Preska were the defendant’s denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity to be heard on this issue before Judge Preska.
51 While the Government is open to crafting a stipulation on the background of the Giuffre lawsuit to streamline presentation of these issues to the jury, it notes that the defendant’s summary of that suit as set forth in her motion is incorrect. (E.g., Def. Mot. 4 at 20 (erroneously asserting that the defamation claims at issue turned on Giuffre’s ability to prove salacious allegations about public officials)).
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DOJ-OGR-00003098
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