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759 KB
Extraction Summary
7
People
3
Organizations
1
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
759 KB
Summary
This legal document, filed on October 29, 2021, is part of the case against Ms. Maxwell. It argues that evidence of Jeffrey Epstein acting alone or without Ms. Maxwell's knowledge should be admissible to counter the government's conspiracy charge. The filing distinguishes Ms. Maxwell's case from several other legal precedents cited by the government, claiming they are inapplicable to the current situation.
People (7)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Alleged co-conspirator |
Mentioned as being in a charged conspiracy with Ms. Maxwell.
|
| Ms. Maxwell | Defendant / Alleged co-conspirator |
The subject of the legal argument, charged in a conspiracy with Jeffrey Epstein.
|
| Dawkins | Defendant |
Mentioned in the case citation United States v. Dawkins.
|
| Scarpa | Defendant |
Mentioned in the case citation United States v. Scarpa.
|
| Chambers | Defendant |
Mentioned in the case citation United States v. Chambers.
|
| Boyce | Party in a lawsuit |
Mentioned in the case citation Boyce v. Weber.
|
| Weber | Party in a lawsuit |
Mentioned in the case citation Boyce v. Weber.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| government | government agency |
Refers to the prosecution in the case against Ms. Maxwell.
|
| 2d Cir. | court |
The United States Court of Appeals for the Second Circuit, cited in several legal cases.
|
| S.D.N.Y. | court |
The United States District Court for the Southern District of New York, cited in a legal case.
|
Timeline (2 events)
The Indictment charged a conspiracy between Jeffrey Epstein and Ms. Maxwell during a discrete time period.
The document discusses the government's burden of proof at Ms. Maxwell's upcoming trial.
Locations (1)
| Location | Context |
|---|---|
|
The location of the court in the cited case Boyce v. Weber.
|
Relationships (1)
The document states that the Indictment charged a conspiracy between them.
Key Quotes (3)
"good"Source
— Legal document (referencing a legal term)
(Describing a type of propensity evidence in cited cases.)
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Quote #1
"bad"Source
— Legal document (referencing a legal term)
(Describing a type of act by a defendant in cited cases.)
DOJ-OGR-00005515.jpg
Quote #2
"disprove government's theory that the defendants congregated ... to discuss the marijuana business"Source
— Finding from United States v. Scarpa
(Quoted as the reason certain evidence was not admissible in the Scarpa case.)
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,250 characters)
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 60 of 69
• the Indictment charged a conspiracy between Jeffrey Epstein and Ms. Maxwell during a discrete time period;
• the charged conspiracy encompasses females other than the four specified Accusers;
• the government's burden at trial will be to show both an agreement between Mr. Epstein and Ms. Maxwell to accomplish the specified illegal objectives;
• the government's burden at trial will also encompass proof beyond a reasonable doubt that Ms. Maxwell had knowledge of the conspiracies' illegal objectives.
Thus, evidence that Jeffrey Epstein acted alone, or with other co-conspirators, without the knowledge or participation of Ms. Maxwell may be admissible as direct evidence of Ms. Maxwell's lack of awareness of or participation in the charged conspiracies. For example, if the government attempts to prove up the conspiratorial agreement or the knowledge of the illegal objective based on a pattern and practice, then evidence that Epstein acted alone or without Ms. Maxwell's knowledge or participation may become relevant.
Each of the cases cited by the government is readily distinguishable. First, all but one of the cases dealt with specific "good" propensity evidence of the defendant, not the absence of a co-conspirator during "bad" acts by the defendant. See United States v. Dawkins, 999 F.3d 767 (2d Cir. 2021) (defendant – not a co-conspirator – proffered evidence that on other occasions he did not bribe other potential targets); United States v. Scarpa, 913 F.2d 993, 1011 (2d. Cir. 1990) (absence of defendants' discussions about drugs on single occasion not admissible to "disprove government's theory that the defendants congregated ... to discuss the marijuana business"); United States v. Chambers, 800 F. App'x 43, 46 (2d. Cir. 2020) (summary order) (fact that defendant also ran a legitimate law practice not admissible to disprove he committed bad acts through illegal practice); Boyce v. Weber, 19 Civ. 3825 (JMF), 2021 WL 2821154, at *8 (S.D.N.Y. July 7, 2021) (defendant's access to other potential victims without engaging in abuse not admissible to establish innocence). Moreover, each of these cases had to do with tendering
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