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Extraction Summary

4
People
3
Organizations
2
Locations
4
Events
3
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 732 KB
Summary

This legal document outlines the defense's argument that it was hindered by the unavailability of old records. Specifically, incomplete travel records from Shoppers Travel prevented them from challenging the testimony of witnesses Annie Farmer and Jane regarding their travel with Epstein. Furthermore, the lack of bank and credit card records from the 1990s and 2000s meant the defense could not contest the government's claims about a $30 million payment from Epstein to Ms. Maxwell or verify other key dates.

People (4)

Name Role Context
Annie Farmer Witness
Mentioned as a witness whose recollection of a trip to New Mexico the defense could not challenge due to a lack of tr...
Jane Witness
A witness who testified she traveled with Epstein as a minor and was sexually abused by him. The defense sought trave...
Epstein Defendant-related individual
Mentioned throughout as the individual with whom witnesses traveled, who owned a private jet, who allegedly committed...
Ms. Maxwell Recipient of funds / Alleged facilitator
Mentioned as the recipient of approximately $30 million from Epstein, which the government argued was payment for fac...

Organizations (3)

Name Type Context
Shoppers Travel company
A travel agency whose records were incomplete due to the passage of time, hindering the defense's ability to challeng...
Bears Sterns company
A financial firm whose statements from 2006-2007 were obtained by the FBI but were the only bank records available re...
Palm Beach FBI government agency
Mentioned as the entity that had obtained Epstein's Bear Stearns statements in 2006-2007.

Timeline (4 events)

1999-2007
Epstein transferred approximately $30 million to Ms. Maxwell.
A trip taken by Annie Farmer to New Mexico.
New Mexico
Jane traveled with Epstein approximately ten times on his private jet and commercial flights while she was under the age of 17.
Jane testified she was first sexually abused by Epstein when she was 14.
New York

Locations (2)

Location Context
A location to which Annie Farmer took a trip, the timing of which was a point of contention for the defense.
The location where witness Jane testified she was first sexually abused by Epstein at age 14.

Relationships (3)

Epstein financial/criminal conspiracy Ms. Maxwell
The government argued that Epstein transferred approximately $30 million to Ms. Maxwell as payment for facilitating his sexual abuse of young girls.
Epstein abuser-victim Jane
Jane testified that she traveled with Epstein as a minor and was sexually abused by him in New York when she was 14.
Epstein acquaintance Annie Farmer
The document mentions a trip Annie Farmer took that the defense wanted to challenge, and that Epstein bought her a pair of cowboy boots.

Full Extracted Text

Complete text extracted from the document (2,155 characters)

Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 32 of 37
topless massage. Tr. 2075. However, because of the passage of time, the available Shoppers Travel records only went back as far as 1999. Tr. 2393. As a result, the defense did not have access to Shoppers Travel records to challenge Annie Farmer’s recollection of when the trip to New Mexico occurred. Likewise, Jane testified that she traveled with Epstein approximately ten times when she was under the age of 17 on both his private jet and on commercial flights, and that she was first sexually abused in New York when she was 14. Tr. 316. As discussed, the flight logs showed only two such trips on Epstein’s plane. The Shoppers Travel records would have shed light on the number of commercial flights that Jane took when she was a minor and could have been used to challenge her recollection of events, including whether she even traveled to New York before she was 16 years old.
B. Financial Documents – Bank Records and Credit Card Records
Critical financial documents were also unavailable to the defense. In its summation, the government gave particular emphasis to bank records which seemed to show that Epstein transferred approximately $30 million to Ms. Maxwell from 1999-2007, arguing that it was Ms. Maxwell’s payment for facilitating his sexual abuse of young girls for over a decade. Tr. 2841, 2884-85. Because the transactions were between 15-20 years old, there were no bank records apart from Epstein’s Bears Sterns statements that the Palm Beach FBI had obtained in 2006-2007 to explain what the transfers were for. The defense was unable to obtain any records related to the accounts into which the money was transferred. The defense therefore could not challenge the government’s claims about the purpose of the funds or that Ms. Maxwell even controlled the accounts.
Furthermore, there were no credit card records available for Epstein going back to the 1990s. Accordingly, the defense could not use these records to test critical dates, like when Epstein bought the pair of cowboy boots for Annie Farmer or the movie tickets to Primal Fear,
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DOJ-OGR-00008956

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