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732 KB
Extraction Summary
4
People
2
Organizations
0
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing / court motion (defense memorandum)
File Size:
732 KB
Summary
This document is a page from a legal filing by Ghislaine Maxwell's defense team, dated March 23, 2021. It argues that the government's case is weakening, citing the 2007 Epstein Non-Prosecution Agreement as a bar to prosecution and claiming the government cannot prove Accuser-3 was a minor during alleged interstate travel. The defense also alleges that prosecutors misled a federal judge to obtain evidence, undermining the integrity of the case.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of detention and prosecution; arguing regarding flight risk and strength of case.
|
| Jeffrey Epstein | Co-conspirator (Deceased) |
Entered into 2007 Non-Prosecution Agreement; alleged to have engaged in sex acts with Accuser-3.
|
| Accuser-3 | Alleged Victim |
Identified as 'Minor Victim-3'; subject of dispute regarding age during travel and sexual acts.
|
| Government Prosecutors | Prosecution |
Accused by defense of misleading a federal judge to obtain evidence.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
Opposing party in the case.
|
|
| The Court |
Entity adjudicating the motions.
|
Timeline (2 events)
2007
Non-Prosecution Agreement entered into by Jeffrey Epstein.
Florida (implied by NPA context)
Jeffrey Epstein
Government
2021-03-23
Relationships (2)
Defense argues Epstein's 2007 NPA immunizes 'potential co-conspirators' including Maxwell.
Document discusses whether Accuser-3 was underage when she 'allegedly engaged in sex acts with Epstein'.
Key Quotes (4)
"Conceded Problems Undermine the Strength of the Government’s Case"Source
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Quote #1
"Ms. Maxwell has persuasively argued that the Non-Prosecution Agreement entered into by Jeffrey Epstein in 2007, which immunizes 'any potential co-conspirators of Epstein,' bars Ms. Maxwell’s prosecution"Source
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Quote #2
"the government concedes it cannot establish that either Ms. Maxwell or Epstein ever caused, or sought to cause, Accuser-3 to travel while she was a minor"Source
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Quote #3
"government prosecutors misled a federal judge to obtain evidence against Ms. Maxwell... a shocking revelation that undermines the viability of the perjury counts"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,108 characters)
Case 1:20-cr-00330-AJN Document 171 Filed 03/23/21 Page 7 of 18
Conceded Problems Undermine the Strength of the Government’s Case
As Ms. Maxwell’s period of detention passes the nine-month mark, the government has continuously upgraded Ms. Maxwell from a “plain [ ] risk of flight” to a “substantial and actual risk of flight” to a “serious flight of risk” and now to an “extreme risk of flight.” (Dkt. 165 at 1.) Ironically, her level of flight risk increases as the strength of government’s case against her diminishes. Ms. Maxwell has challenged the strength of the government’s case in pretrial motions pending before the Court. Among other things, Ms. Maxwell has persuasively argued that the Non-Prosecution Agreement entered into by Jeffrey Epstein in 2007, which immunizes “any potential co-conspirators of Epstein,” bars Ms. Maxwell’s prosecution in this case, and that the counts charging her with alleged sexual abuse are time-barred.
The government’s response to Ms. Maxwell’s pretrial motions shines further light of the weaknesses of its case. For example, the government concedes it cannot establish that either Ms. Maxwell or Epstein ever caused, or sought to cause, Accuser-3⁴ to travel while she was a minor or that she was underage when she allegedly engaged in sex acts with Epstein. (See Opp.162-65 & fn. 57-58.)⁵ Hence, her allegations cannot support the conspiracies charged in the Indictment, leaving the government with only two witnesses to prove the charges against Ms. Maxwell. More importantly, in connection with the government’s response, it produced documents indicating that government prosecutors misled a federal judge to obtain evidence against Ms. Maxwell (see, e.g.,. Opp. Ex. 4-7) - a shocking revelation that undermines the viability of the perjury counts, not to mention the integrity of the entire
⁴ Accuser-3 is identified in the Indictment as “Minor Victim-3.”
⁵ “Opp.” references are to page numbers of the Government’s Omnibus Memorandum in Opposition to Defendant’s Pre-Trial Motions, dated February 26, 2021 and not yet publicly filed.
⁵ “Opp.” references are to page numbers of the Government’s Omnibus Memorandum in Opposition to Defendant’s Pre-Trial Motions, dated February 26, 2021 and not yet publicly filed.
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DOJ-OGR-00001262
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