DOJ-OGR-00008224.jpg
625 KB
Extraction Summary
10
People
3
Organizations
1
Locations
2
Events
3
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
625 KB
Summary
This legal document, filed on December 5, 2021, is a request from the U.S. Government to the Court in case 1:20-cr-00330-PAE. The Government proposes a specific limiting instruction for the jury to be read before a witness, identified as "Witness-3," testifies. The instruction aims to prevent prejudice by clarifying that any testimony about sexual conduct between Witness-3 and Mr. Epstein is not part of the charged crimes and cannot be used to judge the character or propensity of either Mr. Epstein or Ms. Maxwell.
People (10)
| Name | Role | Context |
|---|---|---|
| Witness-3 | Witness |
A witness scheduled to testify about interactions with the Defendant and Mr. Epstein.
|
| Mr. Epstein |
Mentioned in relation to sexual conduct with Witness-3, which is the subject of a proposed jury instruction.
|
|
| Defendant | Defendant |
The individual on trial, who Witness-3 will testify about having interactions with.
|
| Ms. Maxwell |
Mentioned in the proposed jury instruction, stating her character or propensity should not be judged based on Witness...
|
|
| DAMIAN WILLIAMS | United States Attorney |
Submitted the document on behalf of the Government.
|
| Maurene Comey | Assistant United States Attorney |
Listed as one of the attorneys for the Government.
|
| Alison Moe | Assistant United States Attorney |
Listed as one of the attorneys for the Government.
|
| Lara Pomerantz | Assistant United States Attorney |
Listed as one of the attorneys for the Government.
|
| Andrew Rohrbach | Assistant United States Attorney |
Listed as one of the attorneys for the Government.
|
| Defense Counsel | Legal Counsel |
Copied on the document via ECF (Electronic Case Filing).
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
The prosecuting party in the case, requesting a specific jury instruction.
|
| Court | government agency |
The judicial body being addressed in the request.
|
| United States Attorney | government agency |
The office representing the Government, headed by Damian Williams.
|
Timeline (2 events)
2021-12-05
The Government filed a request for a specific jury instruction regarding the upcoming testimony of Witness-3.
Anticipated testimony of Witness-3 regarding interactions with the Defendant and Mr. Epstein.
Courtroom
Locations (1)
| Location | Context |
|---|---|
|
The jurisdiction of the Assistant United States Attorneys handling the case.
|
Relationships (3)
The document states Witness-3 will testify about interactions and sexual conduct she says occurred with Mr. Epstein.
The document states Witness-3 will testify about interactions she says she had with the Defendant.
Both are mentioned together in the context of Witness-3's testimony and the proposed jury instruction, which states the testimony should not be used as a reflection on either of their characters.
Key Quotes (1)
"You will hear testimony from the next witness about interactions that she says she had with the Defendant and Mr. Epstein. I instruct you that because the witness was over the relevant age of consent at the relevant time period, any sexual conduct she says occurred with Mr. Epstein was not “illegal sexual activity” as the Government has charged in the Indictment. For that reason, I have directed the parties not to ask Witness-3 about the details of any sexual conduct she says occurred with Mr. Epstein. I instruct you that this witness is not a victim of the crimes charged in the Indictment. To the extent you conclude that her testimony is relevant to the issues before you, you may consider it. However, you may not convict the Defendant on the basis of the testimony regarding the sexual conduct between this witness and Mr. Epstein. Nor may you consider this testimony as any kind of reflection on Mr. Epstein’s nor Ms. Maxwell’s character or propensity to commit any of the crimes charged in the Indictment."Source
— The Government (proposing it for the Court)
(The full text of the proposed limiting instruction for the jury regarding Witness-3's testimony.)
DOJ-OGR-00008224.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (1,784 characters)
Case 1:20-cr-00330-PAE Document 524 Filed 12/05/21 Page 2 of 2
Accordingly, the Government respectfully requests that the Court inform the jury that the Government and Witness-3 are simply following the Court’s instructions. The Government proposes the following addition to the limiting instruction the Court is already planning to give before Witness-3 testifies.
You will hear testimony from the next witness about interactions that she says she had with the Defendant and Mr. Epstein. I instruct you that because the witness was over the relevant age of consent at the relevant time period, any sexual conduct she says occurred with Mr. Epstein was not “illegal sexual activity” as the Government has charged in the Indictment. For that reason, I have directed the parties not to ask Witness-3 about the details of any sexual conduct she says occurred with Mr. Epstein. I instruct you that this witness is not a victim of the crimes charged in the Indictment. To the extent you conclude that her testimony is relevant to the issues before you, you may consider it. However, you may not convict the Defendant on the basis of the testimony regarding the sexual conduct between this witness and Mr. Epstein. Nor may you consider this testimony as any kind of reflection on Mr. Epstein’s nor Ms. Maxwell’s character or propensity to commit any of the crimes charged in the Indictment.
This addition to the proposed instruction is neutral but mitigates the risk of prejudice to the Government.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
United States Attorney
By: s/
Maurene Comey
Alison Moe
Lara Pomerantz
Andrew Rohrbach
Assistant United States Attorneys
Southern District of New York
Maurene Comey
Alison Moe
Lara Pomerantz
Andrew Rohrbach
Assistant United States Attorneys
Southern District of New York
Cc: Defense Counsel (by ECF)
2
DOJ-OGR-00008224
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