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743 KB
Extraction Summary
2
People
1
Organizations
0
Locations
3
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
743 KB
Summary
This legal document, filed on October 29, 2021, is a request from Defendant Ghislaine Maxwell's counsel to the Court. It argues that the government failed to comply with a September 3, 2021 court order that mandated the disclosure of all alleged co-conspirator identities and statements by October 11, 2021. The filing claims that while the government identified three co-conspirators, including Jeffrey Epstein, it refused to disclose all statements, and therefore asks the Court to prohibit the government from using these statements at trial.
People (2)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Mentioned as the Defendant requesting the Court to preclude the government from introducing co-conspirator statements.
|
| Jeffrey Epstein | Purported co-conspirator |
Identified by the government on October 11, 2021, as one of three purported co-conspirators for the purposes of trial.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Court | government agency |
The judicial body that issued an order on September 3, 2021, and is being requested by the defendant to issue another...
|
Timeline (3 events)
2021-10-11
The government identified three purported co-conspirators, including Jeffrey Epstein, but allegedly failed to disclose all co-conspirator statements as ordered.
government
2021-10-29
Defendant Ghislaine Maxwell filed a document requesting the court to preclude the government from using co-conspirator statements at trial.
Relationships (1)
The document states that on October 11, 2021, the government identified Jeffrey Epstein as one of three 'purported co-conspirators' in the case against Ghislaine Maxwell.
Key Quotes (5)
"does not outweigh the risk of surprise to the Defendant in this case or the need for the parties to litigate co-conspirator issues in advance of trial to ensure the absence of delay"Source
— Court
(From the Court's Order of September 3, 2021, explaining its reasoning for dismissing the government's arguments against disclosure.)
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Quote #1
"disclose to the defense the identities of any unnamed co-conspirators who allegedly participated in the conspiracies charged in the S2 indictment to whom the government will refer at trial."Source
— Court
(A direct requirement from the Court's September 3, 2021 Order to the government.)
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Quote #2
"The Government is FURTHER ORDERED to disclose all co-conspirator hearsay statements it intends to offer at trial no later than October 11, as consistent with this Court’s scheduling order."Source
— Court
(A second, emphasized directive from the Court's September 3, 2021 Order.)
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Quote #3
"all (or any) co-conspirator statements it intends to introduce at trial...."Source
— Ghislaine Maxwell's counsel
(Describing what the government failed and refused to disclose, quoting the scope of the required disclosure.)
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Quote #4
"[t]he Government has produced all co-conspirator statements which"Source
— government
(The government's offered response, which the filing claims circumvents the plain meaning of the Court's Order.)
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,153 characters)
Case 1:20-cr-00330-PAE Document 384 Filed 10/29/21 Page 4 of 12
Defendant Ghislaine Maxwell, through counsel, requests that the Court enter an order precluding the government from introducing any alleged co-conspirator statements under Federal Rule of Evidence 801(d)(2)(E) because the government failed to comply with the Court’s Order of September 3, 2021 (Dkt. 335). In support of this request, Ms. Maxwell states:
RELEVANT PROCEDURAL HISTORY
On multiple occasions Ms. Maxwell requested disclosure of the identity of any alleged co-conspirators in this case along with any statements made by those individuals that the government intends to offer into evidence at trial under Federal Rule of Evidence 801(d)(2)(E).
The Court, on September 3, 2021, dismissed the government’s arguments against disclosure noting that the concern raised by the government about disclosure “does not outweigh the risk of surprise to the Defendant in this case or the need for the parties to litigate co-conspirator issues in advance of trial to ensure the absence of delay” Dkt. 335 at 3. The Order was explicit regarding what the government was required to do: First, no later than October 11, 2021, the government was required to “disclose to the defense the identities of any unnamed co-conspirators who allegedly participated in the conspiracies charged in the S2 indictment to whom the government will refer at trial.” Id. Second, the Court, unambiguously and emphatically, directed: “The Government is FURTHER ORDERED to disclose all co-conspirator hearsay statements it intends to offer at trial no later than October 11, as consistent with this Court’s scheduling order. Dkt. No. 297 at 1.” (emphasis in original.)
On October 11, 2021, the government identified three purported co-conspirators for purposes of trial: Jeffrey Epstein, [REDACTED]. The government, however, failed and refused to disclose “all (or any) co-conspirator statements it intends to introduce at trial....” Instead, the government, circumventing the plain meaning of the Court’s Order, offered that “[t]he Government has produced all co-conspirator statements which
The Court, on September 3, 2021, dismissed the government’s arguments against disclosure noting that the concern raised by the government about disclosure “does not outweigh the risk of surprise to the Defendant in this case or the need for the parties to litigate co-conspirator issues in advance of trial to ensure the absence of delay” Dkt. 335 at 3. The Order was explicit regarding what the government was required to do: First, no later than October 11, 2021, the government was required to “disclose to the defense the identities of any unnamed co-conspirators who allegedly participated in the conspiracies charged in the S2 indictment to whom the government will refer at trial.” Id. Second, the Court, unambiguously and emphatically, directed: “The Government is FURTHER ORDERED to disclose all co-conspirator hearsay statements it intends to offer at trial no later than October 11, as consistent with this Court’s scheduling order. Dkt. No. 297 at 1.” (emphasis in original.)
On October 11, 2021, the government identified three purported co-conspirators for purposes of trial: Jeffrey Epstein, [REDACTED]. The government, however, failed and refused to disclose “all (or any) co-conspirator statements it intends to introduce at trial....” Instead, the government, circumventing the plain meaning of the Court’s Order, offered that “[t]he Government has produced all co-conspirator statements which
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