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656 KB
Extraction Summary
5
People
2
Organizations
1
Locations
2
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
656 KB
Summary
This legal document, part of a court filing on behalf of Ms. Maxwell, argues that the government's case against her is weak and was assembled after Jeffrey Epstein's death. The defense contends the case rests entirely on the uncorroborated testimony of three accusers, with two specific counts relying on a single witness, Minor Victim-1. The filing dismisses the government's 'additional witnesses' as irrelevant, claiming their testimony only confirms that Maxwell and Epstein interacted with minors, which proves nothing.
People (5)
| Name | Role | Context |
|---|---|---|
| Epstein |
Mentioned in the context of accusers' recollections, his alleged sexual abuse of minors, and his death.
|
|
| Ms. Maxwell | Defendant |
The subject of the legal filing, accused of grooming accusers and facilitating sexual abuse. The strength of the evid...
|
| Minor Victim-1 | Witness |
Mentioned as the sole witness for the substantive counts (Counts Two and Four) against Ms. Maxwell.
|
| Jeffrey Epstein |
His death is mentioned as a timeline marker for when the government began issuing subpoenas related to Ms. Maxwell.
|
|
| Turner | Defendant in a cited case |
Mentioned in the case citation 'United States v. Turner' in a footnote.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The government | government agency |
The prosecuting party in the case against Ms. Maxwell. Its evidence and case-building process are being criticized in...
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| The Court | judicial body |
Mentioned in a footnote as having received a letter from a witness and in the context of bail analysis.
|
Timeline (2 events)
The government's case against Ms. Maxwell, which is alleged to be based entirely on the testimony of three accusers.
The death of Jeffrey Epstein, which is presented as a key event preceding the government's issuance of subpoenas related to Ms. Maxwell.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in a case citation as the Eastern District of New York.
|
Relationships (1)
The document discusses allegations that Ms. Maxwell knowingly facilitated or participated in Epstein's sexual abuse of minors. A government memo is quoted stating they 'both...knew and interacted with certain minor victims'.
Key Quotes (5)
"groomed"Source
— Allegation against Ms. Maxwell
(Used to describe the allegation that Ms. Maxwell prepared accusers for Epstein's abuse.)
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Quote #1
"additional witnesses"Source
— The government
(Quoted from a government memorandum (Gov. Mem. at 11) regarding witnesses they plan to call.)
DOJ-OGR-00002213(1).jpg
Quote #2
"outcry"Source
— The government
(Used to describe a type of witness the government's 'additional witnesses' are not.)
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Quote #3
"both [Ms. Maxwell] and Epstein knew and interacted with certain minor victims when those victims were minors."Source
— The government
(Quoted from a government memorandum (Id.) describing the expected testimony of 'additional witnesses'.)
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Quote #4
"met and interacted with"Source
— The government
(A phrase used to describe Ms. Maxwell's contact with a minor, which the document argues 'proves absolutely nothing'.)
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Quote #5
Full Extracted Text
Complete text extracted from the document (1,959 characters)
Case 1:20-cr-00330-AJN Document 103 Filed 12/23/20 Page 7 of 15
here. Whether or not the accusers’ recollections as to Epstein are corroborated is irrelevant to the strength of the evidence against Ms. Maxwell.
The only purported corroboration that pertains in any way to Ms. Maxwell is of marginal value. The government references [REDACTED] (Id. at 11). But even the government concedes that, at best, [REDACTED]
It is clear that the only evidence that Ms. Maxwell allegedly “groomed” the accusers or knowingly facilitated or participated in Epstein’s sexual abuse of minors will come solely from the testimony of the three accusers. The government’s case against Ms. Maxwell therefore rests entirely on the credibility and reliability of these three witnesses.² Moreover, the substantive counts (Counts Two and Four) are based on the testimony of only one witness, Minor Victim-1. It is also telling that the government does not even attempt to rebut the defense’s assertion that it did not begin issuing subpoenas for documents related to Ms. Maxwell until just after the death of Jeffrey Epstein. This confirms that the case against Ms. Maxwell was assembled after the fact
¹ The government also proffers that they will have “additional witnesses.” (Gov. Mem. at 11). But these are not “outcry” witnesses who will corroborate a contemporaneous account of abuse from one or more of the accusers. Instead, they will testify only that “both [Ms. Maxwell] and Epstein knew and interacted with certain minor victims when those victims were minors.” (Id.). Again, the fact that Ms. Maxwell may have “met and interacted with” someone when they were a minor proves absolutely nothing.
² One of the witnesses has submitted a letter to the Court. While the CVRA permits the right to be heard, the letter should be given no legal weight in the Court’s bail analysis. See United States v. Turner, 367 F. Supp. 2d 319, 331-32 (E.D.N.Y. 2005)
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