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616 KB

Extraction Summary

4
People
1
Organizations
0
Locations
2
Events
4
Relationships
4
Quotes

Document Information

Type: Legal document
File Size: 616 KB
Summary

This legal document, filed on April 16, 2021, presents a transcript of testimony where an unnamed defendant is questioned about their knowledge of a scheme by Jeffrey Epstein to recruit underage girls for sexual massages. The defendant denies knowledge, a statement noted as a charged false statement, while their counsel, Mr. Pagliuca, objects. The document also references a related defamation case where a victim, Giuffre, alleged both Epstein and the defendant sexualized a massage, and notes the Government's intent to use this evidence at trial.

People (4)

Name Role Context
Jeffrey Epstein
Subject of questioning regarding a scheme to recruit underage girls for sexual massages and an allegation in a defama...
MR. PAGLIUCA Defense Counsel
Objecting to questions posed to the defendant during a colloquy.
Giuffre Victim / Plaintiff
Mentioned as a victim in a defamation case who alleged Epstein and the defendant sexualized a massage she gave Epstein.
the defendant Defendant
The individual being questioned in the transcript and the subject of the legal arguments presented in the document.

Organizations (1)

Name Type Context
The Government government agency
Mentioned as expecting to introduce evidence and elicit testimony at trial.

Timeline (2 events)

A colloquy where an unnamed defendant was questioned about Jeffrey Epstein's activities. The defendant denied knowledge of a scheme to recruit underage girls.
the defendant MR. PAGLIUCA Unnamed Questioner
A defamation case where Giuffre alleged she was a victim of a scheme and that Epstein and the defendant had sexualized a massage she gave Epstein.

Relationships (4)

the defendant professional Jeffrey Epstein
The document discusses questions about whether the defendant brought underage masseuses to work for Epstein and alleges that Giuffre claimed both the defendant and Epstein sexualized a massage.
Giuffre Victim-Perpetrator Jeffrey Epstein
The document states Giuffre was a victim of a scheme involving Epstein and that she gave him a massage which was allegedly sexualized.
Giuffre Accuser-Accused the defendant
The document states that in a defamation case, Giuffre had alleged that the defendant and Epstein had sexualized a massage that Giuffre gave Epstein.
MR. PAGLIUCA Attorney-Client the defendant
MR. PAGLIUCA is identified as making objections on behalf of the defendant during questioning.

Key Quotes (4)

"I cannot tell you what Jeffrey’s story is. I’m not able to."
Source
— the defendant (An answer given by the defendant to defense counsel prior to the colloquy detailed in the document.)
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Quote #1
"Did Jeffrey Epstein have a scheme to recruit underage girls to use them for purposes of sexual massages?"
Source
— Unnamed Questioner (A question posed to the defendant during a deposition or testimony.)
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Quote #2
"Objection to the form and foundation."
Source
— MR. PAGLIUCA (A legal objection made in response to the questioning of the defendant.)
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Quote #3
"I don’t know what you are talking about."
Source
— the defendant (The defendant's final answer to questions about Epstein's scheme. A footnote indicates this statement is charged as a false statement in the Indictment.)
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Quote #4

Full Extracted Text

Complete text extracted from the document (1,732 characters)

Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 151 of 239
defense counsel and which the defendant ultimately answered by saying “I cannot tell you what Jeffrey’s story is. I’m not able to.” (Id. at 251:13-253:12). This colloquy followed:
Q. Did Jeffrey Epstein have a scheme to recruit underage girls to use them for purposes of sexual massages?
MR. PAGLIUCA: Objection to the form and foundation.
A. Can you ask me again, please?
Q. Did Jeffrey Epstein have a scheme to recruit underage girls to recruit them for sexual massages?
MR. PAGLIUCA: Objection to the form and foundation.
A. Can you ask it a different way?
Q. Did Jeffrey Epstein have a scheme to recruit underage girls for sexual massages?
MR. PAGLIUCA: Objection to the form and foundation.
Q. If you know.
A. I don’t know what you are talking about.⁴⁸
(Ex. 10 at 253:13-254:8).
The defendant argues that the question was ambiguous, as shown by her requests for the questioner to rephrase the question. (Def. Mot. 4 at 9–10, 18). A properly instructed jury could readily conclude otherwise in light of the evidence the Government expects to introduce at trial. The defamation case involved allegations that Giuffre was a victim of that scheme: Giuffre had alleged that Epstein and the defendant had sexualized a massage that Giuffre gave Epstein. The preceding questions focused on (1) whether the defendant brought underage masseuses to work for Epstein, and (2) whether Epstein had a sexual preference for underage girls. Moreover, at trial and as discussed further below, the Government expects to elicit testimony from one or more of
___
⁴⁸ Underlined sentences are charged as false statements in the Indictment.
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