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720 KB
Extraction Summary
4
People
1
Organizations
1
Locations
3
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
720 KB
Summary
This legal document is a portion of a court filing by the prosecution (the "Government") arguing against the defendant's request for a "bill of particulars." The Government contends that the existing 18-page Indictment provides sufficient detail about the charges, which involve conspiracies with Jeffrey Epstein to traffic minors between 1994-1997 and a subsequent cover-up during a 2016 deposition. Citing legal precedents, the prosecution argues that providing more detail would unfairly restrict its case and could allow the defendant to tailor her testimony.
People (4)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein |
Mentioned as the individual with whom the defendant allegedly conspired to engage in illegal sex acts with minor girl...
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| Henry |
Cited in a legal case (Henry, 861 F. Supp. at 1197) as legal precedent.
|
|
| Mitlof |
Cited in a legal case (Mitlof, 2014 WL 4243657) as legal precedent.
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| Samsonov |
Cited in a legal case (United States v. Samsonov) as legal precedent.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Referred to as the prosecuting party in the legal case, arguing against the need for a bill of particulars.
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Timeline (3 events)
1994-1997
The defendant's alleged participation in conspiracies to transport and entice minor girls to engage in illegal sex acts with Jeffrey Epstein.
the defendant
Jeffrey Epstein
2009-01-23
Date of the United States v. Samsonov legal decision cited in the document.
S.D.N.Y.
2016
The defendant's attempt to cover up her conduct during her civil deposition testimony.
the defendant
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the citation for the United States v. Samsonov case, referring to the Southern District of New York.
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Relationships (1)
The document states the defendant is charged with engaging in conspiracies with Jeffrey Epstein to transport and entice minor girls for illegal sex acts.
Key Quotes (5)
"restrict unduly the Government’s ability to present its case."Source
— Henry, 861 F. Supp. at 1197
(A quote from a legal precedent explaining a potential negative consequence of providing a bill of particulars.)
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Quote #1
"care must be taken” because “[t]he government’s presentation of evidence at trial is limited to the particulars contained in the bill"Source
— Mitlof, 2014 WL 4243657, at *2
(A quote from a legal precedent cautioning about the binding nature of a bill of particulars on the prosecution's evidence.)
DOJ-OGR-00003139.jpg
Quote #2
"The vehicle of a bill of particulars serves to inform a defendant of the nature of the charge, when he is otherwise insufficiently informed, and must not be misused to compel disclosure of how much the Government can prove, nor to foreclose the Government from using proof it may develop as the trial approaches."Source
— United States v. Samsonov, No. 07 Cr. 1198 (CM), 2009 WL 176721, at *3 (S.D.N.Y. Jan. 23, 2009)
(A quote from a legal precedent defining the purpose and limitations of a bill of particulars.)
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Quote #3
"tailor her testimony to explain away the Government’s case."Source
— Henry, 861 F. Supp. at 1197
(A quote describing the danger that a defendant might misuse the information from a bill of particulars.)
DOJ-OGR-00003139.jpg
Quote #4
"if the defendant has been given adequate notice of the charges against her and can prepare fully for trial with reasonably diligent efforts, the Government cannot be required to disclose additional details about its case."Source
— Henry, 861 F. Supp. at 1197
(A quote stating the rule that if a defendant has adequate notice, the government is not required to provide more details.)
DOJ-OGR-00003139.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,138 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 205 of 239
to particulars furnished,” it can “restrict unduly the Government’s ability to present its case.” Henry, 861 F. Supp. at 1197; see also Mitlof, 2014 WL 4243657, at *2 (recognizing that “care must be taken” because “[t]he government’s presentation of evidence at trial is limited to the particulars contained in the bill”); United States v. Samsonov, No. 07 Cr. 1198 (CM), 2009 WL 176721, at *3 (S.D.N.Y. Jan. 23, 2009) (“The vehicle of a bill of particulars serves to inform a defendant of the nature of the charge, when he is otherwise insufficiently informed, and must not be misused to compel disclosure of how much the Government can prove, nor to foreclose the Government from using proof it may develop as the trial approaches.”). Moreover, where the Government’s provision of particulars is tantamount to an itemized preview of its proof, it creates the very real danger that a defendant will “tailor her testimony to explain away the Government’s case.” Henry, 861 F. Supp. at 1197. These concerns animate the rule that “if the defendant has been given adequate notice of the charges against her and can prepare fully for trial with reasonably diligent efforts, the Government cannot be required to disclose additional details about its case.” Id.
2. Discussion
There is no basis for a bill of particulars in this case. The charges against the defendant are clear from the face of the Indictment, which provides significant detail regarding the charged crimes. As is apparent from the 18-page Indictment, the charges concern the defendant’s participation in conspiracies to transport and entice minor girls to travel with the intent that they engage in illegal sex acts with Jeffrey Epstein from 1994 through 1997, and the defendant’s attempt to cover up that conduct during her civil deposition testimony in 2016. Specifically, the Indictment makes plain that the defendant is charged with engaging in a conspiracy to transport minor girls with intent that they engage in sexual activity with Epstein, engaging in a conspiracy to entice
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DOJ-OGR-00003139
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