DOJ-OGR-00008958.jpg
749 KB
Extraction Summary
4
People
2
Organizations
5
Locations
4
Events
3
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
749 KB
Summary
This legal document is a filing from the defense in the case against Epstein, arguing that their ability to challenge a witness named Jane's testimony was hampered. The defense claims that unavailable property records and the deaths of key witnesses, specifically architects Alberto Pinto and Roger Salhi, prevented them from proving that Epstein's properties were not constructed or occupied at the times Jane recalled, which would have cast doubt on her testimony.
People (4)
| Name | Role | Context |
|---|---|---|
| Epstein |
Mentioned as the owner of several properties (71st Street townhouse, New Mexico ranch, Palm Beach house, New York res...
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| Jane | Witness |
A witness who testified about a trip to Epstein's ranch in New Mexico when she was "15 or 16."
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| Alberto Pinto | Architect |
A deceased witness described as an architect who built, renovated, and decorated many of Epstein's residences.
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| Roger Salhi | Architect |
A deceased witness described as an architect who built, renovated, and decorated many of Epstein's residences.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| the defense | legal team |
Mentioned throughout as the party arguing they could not challenge a witness's testimony due to unavailable records a...
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| the government | government agency |
Mentioned as the opposing party whose proof the defense sought to contradict.
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Timeline (4 events)
Locations (5)
| Location | Context |
|---|---|
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An Epstein residence that the defense believes he did not occupy until 1996.
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Location of Epstein's ranch.
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The location Jane testified about visiting. The defense argues the main house was not completed until the late 1990s.
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Location of one of Epstein's houses that was renovated in the mid-1990s.
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One of Epstein's residences worked on by architects Pinto and Salhi.
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Relationships (3)
Alberto Pinto was an architect who built, renovated, and decorated many of Epstein's residences.
Roger Salhi was an architect who built, renovated, and decorated many of Epstein's residences.
Key Quotes (1)
"giant ranch sort of in the middle of nowhere … [which] seemed very empty on the interior."Source
— Jane
(Quoted from her testimony (Tr. 321) describing Epstein's ranch in New Mexico.)
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Quote #1
Full Extracted Text
Complete text extracted from the document (2,259 characters)
Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 34 of 37
the defense had substantial reason to believe that Epstein did not start living in the 71st Street townhouse until the beginning of 1996. Had property records for the 71st Street townhouse been available, they could have rebutted Jane’s testimony and challenged the accuracy of her recollection.
Similarly, when Jane testified about her trip to Epstein’s ranch in New Mexico when she was “15 or 16,” she recalled staying at a “giant ranch sort of in the middle of nowhere … [which] seemed very empty on the interior.” Tr. 321. From her description, it is clear that Jane was referring to the large ranch house that Epstein constructed on the property, and not the triple-wide trailer where he stayed while the large house was under construction. The defense had significant reason to believe that the large ranch house was not completed until the end of the 1990s, when Jane would have been closer to 18 or 19 years old. But because property records showing the dates of construction were not available, the defense could not challenge Jane’s recollection with contrary documentary evidence.
E. Deceased Witnesses
Finally, in the over 20-year period that elapsed from the time of the charged conduct to the time of trial, numerous potential witnesses who could have provided evidence contradicting the government’s proof had died. In addition to the ones already mentioned in our previous filings, the following individuals, among others, were no longer available to the defense:
• Alberto Pinto and Roger Salhi – Mr. Pinto and Mr. Salhi were architects who built, renovated, and decorated many of Epstein’s residences, including the house in Palm Beach, the New York residence, and the ranch in New Mexico. The defense believes they could have established (i) when Epstein moved into the 71st Street townhouse and what it looked like inside over the relevant time period, (ii) when the large ranch house was built, and (iii) that the Palm Beach residence was being renovated for almost a year in the mid-1990s and that Epstein had to move into a rental house during renovation. All of this evidence would have cast significant doubt on Jane’s recollection of events.
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DOJ-OGR-00008958
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