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675 KB

Extraction Summary

6
People
2
Organizations
2
Locations
3
Events
4
Relationships
2
Quotes

Document Information

Type: Legal document
File Size: 675 KB
Summary

This legal document, filed on December 15, 2021, discusses the defendant's attempt to introduce statements from Robert Glassman to impeach a witness named Jane. The document details Jane's evolving testimony about a trip to New York with Epstein and the defendant to see 'The Lion King,' noting that her corrected recollections were communicated to the Government by her lawyer. The prosecution argues that Glassman's testimony on these same points is unnecessary and that questions about Jane's conversations with him were met with sustained objections.

People (6)

Name Role Context
Edwards
Mentioned in the context of anticipated testimony about a U-Visa, which is deemed inadmissible.
Scarola
Mentioned as another individual whose testimony is being used as a reason to preclude Edwards's testimony.
Robert Glassman
A central figure in this section, whose statements and communications are being discussed for potential use in litiga...
Jane Witness/Victim
A witness whose testimony and recollections about a trip with Epstein are being scrutinized. Referred to by the pseud...
Epstein
Mentioned as the person who took Jane to New York to see The Lion King and who allegedly bragged about getting the se...
Jane's lawyer Lawyer
Mentioned as having communicated Jane's corrected recollection to the government.

Organizations (2)

Name Type Context
Government government agency
Mentioned as the recipient of communications from Glassman and Jane's lawyer regarding Jane's recollections and timel...
EVCP government agency
Referred to as 'the Program' from which Glassman sought a larger award. Likely a victim compensation program.

Timeline (3 events)

Jane flew to New York with Epstein and the defendant to see The Lion King when she was 14. She later corrected her testimony, stating this trip was separate from another event in her timeline.
New York
Jane Epstein defendant
Jane, Epstein, and the defendant saw The Lion King on Broadway, sitting in mezzanine seats.
Broadway
Jane Epstein defendant
The defense cross-examined Jane at length about her timeline and recollection of the trip to see The Lion King.
Court
Jane defense

Locations (2)

Location Context
The destination where Jane, Epstein, and the defendant flew to see The Lion King.
The location of The Lion King show that Jane attended.

Relationships (4)

Jane associates Epstein
Epstein took Jane on a trip to New York.
Jane associates defendant
The defendant accompanied Jane and Epstein on a trip to New York.
Jane professional Robert Glassman
Jane had conversations with Glassman, and Glassman communicated with the Government about Jane's recollections.
Robert Glassman professional Government
Glassman had an 'exchange' with the Government concerning Jane's testimony.

Key Quotes (2)

"lawyer communicated to the government [Jane's] recollection that, in fact, [she] had seen The Lion King Broadway show and not the movie."
Source
— Jane (acknowledging her lawyer's action) (Jane acknowledging during testimony that her lawyer had corrected her initial statement to the government about seeing The Lion King.)
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Quote #1
"bragged about getting those seats because he knew the director,"
Source
— Epstein (A detail confirmed by Jane during her testimony, describing what Epstein said about obtaining the mezzanine seats for The Lion King.)
DOJ-OGR-00008380.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (1,945 characters)

Case 1:20-cr-00330-PAE Document 545 Filed 12/15/21 Page 7 of 9
testimony. Edwards's anticipated testimony about the U-Visa is therefore inadmissible, and in any event, should be precluded under Rule 403 for the same reasons as testimony from Scarola.
C. Robert Glassman
In addition to the Glassman's statement which is already the subject of litigation, the defendant identifies two additional statements which she seeks to offer: (1) Glassman's exchange with the Government about Jane's recollection of seeing The Lion King on Broadway, and (2) Glassman's communications with the EVCP in which Glassman sought a larger award from the Program.
Jane's statements in The Lion King e-mail do not impeach Jane's testimony. Jane acknowledged that she originally told the Government that she flew to New York first with Epstein and the defendant to see The Lion King when she was 14, but she later realized she was incorrect in her timeline, and she saw the show on a different trip. (Tr. 503). The defense cross-examined her on this point at length (Tr. 503-12). After her recollection was refreshed with the specific email attached as Exhibit 1 to the defendant's letter, Jane also acknowledged that her “lawyer communicated to the government [Jane's] recollection that, in fact, [she] had seen The Lion King Broadway show and not the movie.” (Tr. 509-10). She confirmed details, including that she sat in mezzanine seats and that Epstein “bragged about getting those seats because he knew the director,” and that all of that information was conveyed to the Government in response to questions about her timeline from the Government. (Tr. 510-11).
Jane confirmed every question the defense asked about the content of this email, except questions which drew sustained objections because they asked Jane about the substance of her conversations with Glassman. (Tr. 510-12). Calling Glassman to testify to the same information
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