DOJ-OGR-00003141.jpg
694 KB
Extraction Summary
4
People
1
Organizations
1
Locations
1
Events
1
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
694 KB
Summary
This legal document, filed on April 16, 2021, is part of a prosecution's argument against a defendant's request for a bill of particulars. The prosecution contends that the indictment is sufficiently detailed and that the defendant has already received over 2.7 million pages of discovery, making further specifics unnecessary. A footnote reveals that the Government was unable to obtain records of commercial flights taken by the defendant, Epstein, or any victims because the investigation was opened after the records were no longer available.
People (4)
| Name | Role | Context |
|---|---|---|
| Torres |
Quoted in a legal citation (quoting Torres, 901 F.2d at 234).
|
|
| Chen |
Mentioned as a party in a legal citation (United States v. Chen, 378 F.3d 151, 163 (2d Cir. 2004))).
|
|
| Wedd |
Mentioned as a party in a legal citation (United States v. Wedd, No. 15 Cr. 616 (KBF), 2016 WL 1055737).
|
|
| Epstein |
Mentioned in footnote 61 regarding the unavailability of commercial flight records for him, the defendant, or any vic...
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Mentioned as the prosecuting party, arguing against the defendant's motion. Also mentioned in footnote 61 as not havi...
|
Timeline (1 events)
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in a legal citation as the court for the Southern District of New York (S.D.N.Y. Mar. 10, 2016).
|
Relationships (1)
Footnote 61 groups 'the defendant, Epstein, or any victims' together when discussing the unavailability of commercial flight records.
Key Quotes (2)
"so general that they do not advise the defendant of the specific acts of which he is accused."Source
— Torres (quoted)
(A quote from a legal precedent (Torres, 901 F.2d at 234) defining when particulars are necessary for an indictment.)
DOJ-OGR-00003141.jpg
Quote #1
"the Indictment is a ‘speaking’ Indictment that provides a significant amount of detail as to the Government’s theory of the case and the nature of the proof that will underlie the charges at trial"Source
— United States v. Wedd case
(A quote from a legal precedent (United States v. Wedd) used to argue that the current indictment is sufficiently detailed.)
DOJ-OGR-00003141.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,018 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 207 of 239
Particulars are necessary only where indictment charges are ‘so general that they do not advise the
defendant of the specific acts of which he is accused.’” (internal citation omitted) (quoting Torres,
901 F.2d at 234; United States v. Chen, 378 F.3d 151, 163 (2d Cir. 2004))); United States v. Wedd,
No. 15 Cr. 616 (KBF), 2016 WL 1055737, at *3 (S.D.N.Y. Mar. 10, 2016) (denying motion for
bill of particulars where “the Indictment is a ‘speaking’ Indictment that provides a significant
amount of detail as to the Government’s theory of the case and the nature of the proof that will
underlie the charges at trial”).
defendant of the specific acts of which he is accused.’” (internal citation omitted) (quoting Torres,
901 F.2d at 234; United States v. Chen, 378 F.3d 151, 163 (2d Cir. 2004))); United States v. Wedd,
No. 15 Cr. 616 (KBF), 2016 WL 1055737, at *3 (S.D.N.Y. Mar. 10, 2016) (denying motion for
bill of particulars where “the Indictment is a ‘speaking’ Indictment that provides a significant
amount of detail as to the Government’s theory of the case and the nature of the proof that will
underlie the charges at trial”).
Additional particularity relating to the details of the counts in the Indictment might be
helpful for the defendant, but that is both true in every case and not the appropriate standard.
Instead, the inquiry is properly focused on whether the information already available to her is so
general that a bill of particulars is necessary to the preparation of her defense. Plainly it is not. In
addition to the speaking Indictment, the defendant has received over 2.7 million pages of discovery
in this case. Although that is a high volume of discovery, it is clear from the defense’s own motion
that the defense has apparently already reviewed that material (at least in significant part),
identified relevant materials therein, and is aware of their relevance to the allegations in the
Indictment. (See, e.g., Def. Mot. 10 at 6). Indeed, much of the discovery is text searchable, and
the time period that each document relates to is readily ascertainable.
helpful for the defendant, but that is both true in every case and not the appropriate standard.
Instead, the inquiry is properly focused on whether the information already available to her is so
general that a bill of particulars is necessary to the preparation of her defense. Plainly it is not. In
addition to the speaking Indictment, the defendant has received over 2.7 million pages of discovery
in this case. Although that is a high volume of discovery, it is clear from the defense’s own motion
that the defense has apparently already reviewed that material (at least in significant part),
identified relevant materials therein, and is aware of their relevance to the allegations in the
Indictment. (See, e.g., Def. Mot. 10 at 6). Indeed, much of the discovery is text searchable, and
the time period that each document relates to is readily ascertainable.
In this vein, the defendant has received [REDACTED]
[REDACTED].61
[REDACTED]
61 Records of commercial flights were unavailable by the time the Government opened its
investigation in this case. Accordingly, the Government has no records of commercial flights that
the defendant, Epstein, or any victims may have taken during the relevant period.
investigation in this case. Accordingly, the Government has no records of commercial flights that
the defendant, Epstein, or any victims may have taken during the relevant period.
180
DOJ-OGR-00003141
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document