DOJ-OGR-00005779.jpg
542 KB
Extraction Summary
2
People
1
Organizations
2
Locations
4
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
542 KB
Summary
This legal document is a motion arguing for the exclusion of certain evidence in the case against Ms. Maxwell. The defense claims that a photograph of Maxwell found at Jeffrey Epstein's house (Exhibit 313) and a "Household Manual" dated 2005 (Exhibit 606) are irrelevant and unfairly prejudicial. The document cites legal standards, such as Rule 401, to argue that this evidence has no bearing on the case and was created outside the timeframe of the alleged indictment.
People (2)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant (implied) |
Subject of a photograph (Government Exhibit 313) and a document titled "Household Manual" (Government Exhibit 606) wh...
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| Jeffrey Epstein |
A photograph of Ms. Maxwell was seized from a DVD disk found in his house during a search in 2019.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Mentioned as the source of 'Government Exhibit 313' and 'Government Exhibit 606'.
|
Timeline (4 events)
2005-02-14
The alleged creation date of a document titled “Household Manual”, as suggested by a date on the document.
2019
A search of Jeffrey Epstein's house where a DVD disk in a binder containing a photograph of Ms. Maxwell was seized.
Jeffrey Epstein’s house
Locations (2)
| Location | Context |
|---|---|
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Location where a DVD disk containing a photograph of Ms. Maxwell was seized in 2019.
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|
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Location where photographs of Ms. Maxwell were found in 2019.
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Relationships (1)
A photograph of Ms. Maxwell was found on a DVD disk in Jeffrey Epstein's house.
Key Quotes (3)
"has any tendency to make a fact more or less probable than it would be without the evidence,"Source
— Rule 401
(A quote from Federal Rule of Evidence 401 defining relevant evidence.)
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Quote #1
"the fact is of consequence in determining the action."Source
— Rule 401
(A quote from Federal Rule of Evidence 401 defining relevant evidence.)
DOJ-OGR-00005779.jpg
Quote #2
"The term ‘unfair prejudice,’ as to a criminal defendant, speaks to the capacity of some concededly relevant evidence to lure the factfinder into declaring guilt on a ground different"Source
— Legal definition
(A quote defining 'unfair prejudice' in the context of excluding evidence against a criminal defendant.)
DOJ-OGR-00005779.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,916 characters)
Case 1:20-cr-00330-PAE Document 396 Filed 10/29/21 Page 5 of 8
Government Exhibit 313 purports to be a photograph of Ms. Maxwell, purportedly seized from a DVD disk in a binder found on a shelf in Jeffrey Epstein’s house when it was searched in 2019. There is no nexus between any allegation in this case and the photograph.
Government Exhibit 606 is a document titled “Household Manual” which was apparently printed from an unidentified computer or other electronic storage device. There is no evidentiary foundation for this document, it is hearsay, and the one date on the document, “2/14/2005,” suggests that it was created after the events alleged in the indictment. Ms. Maxwell did not create the document and no evidence exists suggesting that she did.
II. The Items are Not Relevant
Rule 401 defines relevant evidence as that which “has any tendency to make a fact more or less probable than it would be without the evidence,” so long as “the fact is of consequence in determining the action.” Fed. R. Evid. 401; see also Old Chief v. United States, 519 U.S. 172, 178 (1997).
There is no evidence that any accuser in this case saw, was aware of, or impacted by any of the above listed items. [REDACTED]
Similarly, the apparent seizure of the “Twin Torpedos” in 2005 is not probative of anything.
Photographs of Ms. Maxwell found in a NY closet in 2019 prove no material fact in this case not otherwise established by less prejudicial evidence as discussed below.
Finally, the unauthenticated 2005 “Household Manual” is outside the time frame alleged in the indictment and plays no role in any allegation contained in the indictment.
III. The Evidence Should Be Excluded as Unfairly Prejudicial
“The term ‘unfair prejudice,’ as to a criminal defendant, speaks to the capacity of some concededly relevant evidence to lure the factfinder into declaring guilt on a ground different
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DOJ-OGR-00005779
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