DOJ-OGR-00002681.jpg
730 KB
Extraction Summary
5
People
1
Organizations
1
Locations
3
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
730 KB
Summary
This legal document, filed on behalf of Ms. Maxwell, argues for the removal of allegations concerning 'Accuser-3' from her indictment. The defense contends that these allegations are irrelevant to the charges of enticing travel for unlawful sexual activity, as there is no claim Accuser-3 ever traveled for such a purpose, and that the alleged activity with Epstein was not unlawful because Accuser-3 was over the age of consent in England. The filing asserts that the government's inclusion of these claims is a prejudicial attempt to demonstrate a propensity for wrongdoing, in violation of federal evidence rules.
People (5)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
The subject of the legal filing, arguing to strike allegations against her from an indictment.
|
| Epstein |
Mentioned in connection with alleged "sexual abuse" of Accuser-2 and Accuser-3, in which Ms. Maxwell was allegedly co...
|
|
| Accuser-1 | Accuser |
Mentioned in the indictment with a specific allegation of travel.
|
| Accuser-2 | Accuser |
An individual whose alleged "sexual abuse" by Epstein the government claims Ms. Maxwell was complicit in.
|
| Accuser-3 | Accuser |
The central figure in this part of the document; the defense argues that allegations concerning her should be stricke...
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| government | government agency |
The prosecuting party in the case against Ms. Maxwell, alleged to be including prejudicial allegations in the indictm...
|
Timeline (3 events)
2021-02-04
Filing of Document 146 in Case 1:20-cr-00330-AJN, arguing to strike allegations regarding Accuser-3.
Alleged "sexual abuse" of Accuser-2 and Accuser-3 by Epstein, in which the government alleges Ms. Maxwell was complicit.
A specific allegation of travel by Accuser-1 mentioned in the indictment.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned as the location where Accuser-3 was over the legal age of consent.
|
Relationships (3)
The document states the government alleges Ms. Maxwell was complicit in Epstein's alleged 'sexual abuse' of others, suggesting a collaborative relationship in the context of the alleged crimes.
The government has included allegations regarding Ms. Maxwell's interactions with Accuser-3 in the indictment. Ms. Maxwell's legal team is arguing these allegations are prejudicial and should be stricken.
Full Extracted Text
Complete text extracted from the document (2,131 characters)
Case 1:20-cr-00330-AJN Document 146 Filed 02/04/21 Page 6 of 16
conduct that allegedly took place more than two decades ago—accusations so vague that they do not even link Ms. Maxwell to the only specific allegation of travel by Accuser-1 in the indictment (see Indictment ¶¶ 11b, 17b).
To try to bolster its case, the government alleges that Ms. Maxwell was complicit in Epstein’s alleged “sexual abuse” of two other individuals, Accuser-2 and Accuser-3, and has included allegations regarding Ms. Maxwell’s interactions with these two individuals in the indictment. But the allegations as to Accuser-3 cannot possibly support the charges against Ms. Maxwell: Although the gravamen of a § 2422(a) or § 2423(a) offense is enticing or causing an individual to travel, there is no allegation that Accuser-3 ever traveled—let alone that Ms. Maxwell (or Epstein, for that matter) enticed her to do so or transported her. Moreover, although both § 2422(a) and § 2423(a) require an intent that the traveling individual engage in unlawful sexual activity, the indictment alleges no facts suggesting that Epstein’s alleged sexual activity with Accuser-3, who was over the legal age of consent in England at all relevant times, was unlawful. As a result, these allegations serve only to demonstrate a propensity on the part of Ms. Maxwell that will prejudice the jury against her.
To enable the presentation of evidence regarding Accuser-3, the government claims the alleged “sexual abuse” of Accuser-3 is somehow an “overt act” in furtherance of conspiracies to cause unspecified individuals to travel for the purpose of engaging in unlawful sexual activity. The government’s inclusion of these allegations, however, is nothing more than an attempted end-run around its obligations under Fed. R. Evid. 404(b). The “overt act” alleged as to Accuser-3 has nothing to do with the alleged conspiracy. Moreover, the allegations regarding Accuser-3 are unduly prejudicial to Ms. Maxwell. Accordingly, Ms. Maxwell requests that the allegations regarding Accuser-3 be stricken as surplusage, or in the alternative, that the
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DOJ-OGR-00002681
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