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672 KB
Extraction Summary
8
People
4
Organizations
1
Locations
3
Events
0
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
672 KB
Summary
This legal document, a page from a court filing dated October 29, 2021, argues that the jury should not consider the adequacy or methods of the government's investigation when determining a defendant's guilt. Citing multiple legal precedents, the author contends that details about investigations, including the one involving Jeffrey Epstein, are irrelevant to the case at hand. The document refutes the defense's position that they should be allowed to challenge the thoroughness of the government's investigation.
People (8)
| Name | Role | Context |
|---|---|---|
| Miles | Defendant |
Mentioned in the case citation United States v. Miles.
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| Carton | Defendant |
Mentioned in the case citation United States v. Carton.
|
| Saldarriaga | Defendant |
Mentioned in the case citation United States v. Saldarriaga.
|
| Jeffrey Epstein |
Mentioned as an example of an investigation whose details (including his death) are not relevant to the current case.
|
|
| Duncan | Defendant |
Mentioned in the case citation United States v. Duncan.
|
| Aleynikov | Defendant |
Mentioned in the case citation United States v. Aleynikov.
|
| Kyles | Petitioner |
Mentioned in the case citation Kyles v. Whitley, quoted by the defense.
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| Whitley | Respondent |
Mentioned in the case citation Kyles v. Whitley, quoted by the defense.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States Government | government agency |
Referred to as "the Government" and is the prosecuting party in several cited cases. The document argues that the Gov...
|
| USAO-SDFL | government agency |
Mentioned as an entity that opened an investigation, the details of which are argued to be irrelevant. Likely stands ...
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| 2d Cir. | court |
The Second Circuit Court of Appeals, cited in several case precedents (Miles, Saldarriaga, Aleynikov).
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| S.D.N.Y. | court |
The Southern District of New York court, cited in several case precedents (Carton, Duncan, Aleynikov).
|
Timeline (3 events)
2018-10-19
2019-05-22
Locations (1)
| Location | Context |
|---|---|
|
Referenced by the abbreviation S.D.N.Y. as the location of several court cases.
|
Key Quotes (5)
"the Government is not on trial in this case, and the jury will not be asked to pass on the adequacy of its investigation."Source
— United States v. Carton
(Quoted to support the argument that the jury's role is not to evaluate the government's investigation.)
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Quote #1
"in light of [the] evidence or lack of evidence, the jury [is] convinced beyond a reasonable doubt that the defendant was guilty of the crimes with which [she is] charged."Source
— United States v. Saldarriaga
(Quoted to define the issue before the jury, focusing on the defendant's guilt based on evidence presented.)
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Quote #2
"The length of the investigation, the investigative techniques used, and the fact that [the defendant] was not initially a target of the investigation are all irrelevant pursuant to this principle."Source
— United States v. Duncan
(Quoted to argue that specific details of the government's investigation are irrelevant to the defendant's guilt.)
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Quote #3
"As a general matter, the quality and scope of the Government’s investigation are not appropriate lines of examination . . . ."Source
— United States v. Aleynikov
(Quoted to reinforce the principle that the government's investigation methods should not be scrutinized by the jury.)
DOJ-OGR-00005580.jpg
Quote #4
"thoroughness and even the good faith of the [government’s] investigation."Source
— Kyles v. Whitley (quoted by the defense)
(A phrase from a case cited by the defense to argue they should be allowed to challenge the government's investigation.)
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Quote #5
Full Extracted Text
Complete text extracted from the document (1,972 characters)
Case 1:20-cr-00330-PAE Document 383 Filed 10/29/21 Page 26 of 40
United States v. Miles, 748 F.3d 485, 489 (2d Cir. 2014) (per curiam) (citation and internal quotation marks omitted).
It is elementary that “the Government is not on trial in this case, and the jury will not be asked to pass on the adequacy of its investigation.” United States v. Carton, No. 17 Cr. 680 (CM), 2018 WL 5818107, at *3 (S.D.N.Y. Oct. 19, 2018). The issue before the jury is simply whether, “in light of [the] evidence or lack of evidence, the jury [is] convinced beyond a reasonable doubt that the defendant was guilty of the crimes with which [she is] charged.” United States v. Saldarriaga, 204 F.3d 50, 52 (2d Cir. 2000) (per curiam). Accordingly, there is no basis to offer evidence about why the Government or the USAO-SDFL opened their respective investigations, how they resolved those investigations, or the death of Jeffrey Epstein. These issues simply do not relate to the defendant’s guilt or innocence of the charged crimes. See United States v. Duncan, No. 18 Cr. 289 (SHS), 2019 WL 2210663, at *3 (S.D.N.Y. May 22, 2019) (“The length of the investigation, the investigative techniques used, and the fact that [the defendant] was not initially a target of the investigation are all irrelevant pursuant to this principle.”); United States v. Aleynikov, 785 F. Supp. 2d 46, 65 (S.D.N.Y. 2011) (“As a general matter, the quality and scope of the Government’s investigation are not appropriate lines of examination . . . .”), rev’d on other grounds, 676 F.3d 71 (2d Cir. 2012).
The defense argues that they are free to offer whatever evidence they like in order to challenge the “thoroughness and even the good faith of the [government’s] investigation.” (Def. Opp. at 32 (quoting Kyles v. Whitley, 514 U.S. 419, 445 (1995))). In support, the defense cites three decades-old cases, none from this Circuit or any district in this Circuit. All arise under very
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DOJ-OGR-00005580
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