EFTA00031259.pdf
139 KB
Extraction Summary
5
People
4
Organizations
2
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal witness examination script / q&a outline
File Size:
139 KB
Summary
This document is a Q&A script for the examination of Paul Kane, Director of Finance at Professional Children's School, used in the trial of Ghislaine Maxwell. The prosecution uses Kane to authenticate a student application record (GX 761) from the early 1990s as a business record. The key evidence highlighted is that 'JE' (Jeffrey Epstein) was listed on the application as the person financially responsible for the tuition of a student moving to New York from West Palm Beach, Florida.
People (5)
| Name | Role | Context |
|---|---|---|
| Paul Kane | Witness / Director of Finance |
Director of Finance at Professional Children's School; testifying to authenticate business records.
|
| Ghislaine Maxwell | Defendant |
Named in the case caption: United States v. GHISLAINE MAXWELL.
|
| JE | Financial Sponsor |
Jeffrey Epstein (referenced as JE). Listed as the person with financial responsibility for the student applicant.
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| Unnamed Student | Applicant |
Student applying for grade 12 at PCS; previously attended school in WPB, Florida; moved to New York.
|
| President of Admissions at Julliard | Referral Source |
Referred the student to PCS.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Professional Children's School |
Employer of the witness; school where the student applied.
|
|
| PCS |
Abbreviation for Professional Children's School.
|
|
| Julliard |
Juilliard School; President of Admissions referred the student.
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|
| International Preschools |
Previous employer of Paul Kane.
|
Timeline (2 events)
2011-2012
Digitization of paper student files at Professional Children's School.
Professional Children's School
Locations (2)
| Location | Context |
|---|---|
|
West Palm Beach; location of student's previous high school.
|
|
|
Location the student moved to.
|
Relationships (2)
JE listed as person with financial responsibility for student's tuition on application.
Director of Finance since 2019.
Key Quotes (4)
"If must: offering for fact of application, and for the state-of-mind statement that JE was going to pay for her tuition."Source
EFTA00031259.pdf
Quote #1
"Turning to page 2, Section E, who is listed as the person with financial responsibility for this applicant? Answer: JE"Source
EFTA00031259.pdf
Quote #2
"Where did the student attend high school previously? Answer: WPB, Florida"Source
EFTA00031259.pdf
Quote #3
"Why did the student leave? Answer: Moved to New York"Source
EFTA00031259.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (4,414 characters)
United States v. GHISLAINE MAXWELL, 20 Cr. 330 (AJN)
Paul Kane Q&A
Objectives GX 761
Rule 803(6)
- Record made at or near the time by --- or from information transmitted by ---
someone with knowledge
- Kept in the course of a regularly conducted activity of a business
- Making the record was the regular practice of that activity
Rule 803(6)
- Record made at or near the time by --- or from information transmitted by ---
someone with knowledge
- Kept in the course of a regularly conducted activity of a business
- Making the record was the regular practice of that activity
BACKGROUND
Question | Answer | Rule
Mr. Kane, where do you work? | Professional Children’s School |
What is Professional Children’s School? | |
What is your title? | Director of Finance |
How long have you worked there? | 2019 |
What did you do before that? | Chief Admin Officer at international preschools from 2009 to 2019 |
Are those private schools? | Yes |
What are your responsibilities? | All financial oversight, archives, financial aspects of enrollment |
In that capacity, are you familiar with the normal business practices of Professional Children’s School? | Yes |
Are you familiar with the business practices regarding student files? | Yes |
Are you familiar with how those practices worked in the early 1990s? How? | Through archives and conversations with other employees who have been there longer |
What are student files? | PCS keeps a permanent file on each student |
Does PCS regularly maintain student files? | Yes |
How are those records maintained? | Electronically |
How did it work in the 1990s? | Paper |
What happened to paper files? | Digitized in about 2011/12 |
What sort of information is contained in the student record? | Transcript, college recs, admissions info |
Are those records regularly put in the student file at the time they are created? | Yes |
Question | Answer | Rule
Mr. Kane, where do you work? | Professional Children’s School |
What is Professional Children’s School? | |
What is your title? | Director of Finance |
How long have you worked there? | 2019 |
What did you do before that? | Chief Admin Officer at international preschools from 2009 to 2019 |
Are those private schools? | Yes |
What are your responsibilities? | All financial oversight, archives, financial aspects of enrollment |
In that capacity, are you familiar with the normal business practices of Professional Children’s School? | Yes |
Are you familiar with the business practices regarding student files? | Yes |
Are you familiar with how those practices worked in the early 1990s? How? | Through archives and conversations with other employees who have been there longer |
What are student files? | PCS keeps a permanent file on each student |
Does PCS regularly maintain student files? | Yes |
How are those records maintained? | Electronically |
How did it work in the 1990s? | Paper |
What happened to paper files? | Digitized in about 2011/12 |
What sort of information is contained in the student record? | Transcript, college recs, admissions info |
Are those records regularly put in the student file at the time they are created? | Yes |
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United States v. GHISLAINE MAXWELL, 20 Cr. 330 (AJN)
Were they in the 1990s? | Yes |
How long are student records kept? | 6 years |
Are those records kept in the ordinary course of business? | Yes |
What happens at the end of that time? | Destroyed |
Are they always purged from the file at the completion of that time? | No |
How long are student records kept? | 6 years |
Are those records kept in the ordinary course of business? | Yes |
What happens at the end of that time? | Destroyed |
Are they always purged from the file at the completion of that time? | No |
I am handing you what has been marked for identification as GX 761. Do you recognize this document? | Yes |
Without saying any names, what is it? | Application |
Did you review this prior to today? | Yes |
How? [Did you compare it with the records from PCS’s files database] | This student’s electronic file is digitized |
Is this a true and accurate copy of the document at PCS? | Yes |
Government offers 761
Without saying any names, what is it? | Application |
Did you review this prior to today? | Yes |
How? [Did you compare it with the records from PCS’s files database] | This student’s electronic file is digitized |
Is this a true and accurate copy of the document at PCS? | Yes |
Government offers 761
• These are business records
o Admissions records:
▪ Business records. Doesn’t matter whether student or school actually put the information on the school’s form.
▪ In any event, “made” by school when received and relied on in ordinary course of business – adopted business records doctrine.
▪ If must: offering for fact of application, and for the state-of-mind statement that JE was going to pay for her tuition. Not offered for truth: not saying he was actually going to do it.
o Admissions records:
▪ Business records. Doesn’t matter whether student or school actually put the information on the school’s form.
▪ In any event, “made” by school when received and relied on in ordinary course of business – adopted business records doctrine.
▪ If must: offering for fact of application, and for the state-of-mind statement that JE was going to pay for her tuition. Not offered for truth: not saying he was actually going to do it.
EXTRA FOUNDATION [if necessary]
Question | Answer | Rule
Mr. Kane, a few more questions about this document | |
Where does the form come from? | PCS |
Who filles out the application? | The student |
When an application is received by PCS, what happens? | |
Is PCS in the regular practice of receiving and maintaining applications for admission? | |
What efforts does PCS make to verify the information on the application? | [confirm with Kane] |
Question | Answer | Rule
Mr. Kane, a few more questions about this document | |
Where does the form come from? | PCS |
Who filles out the application? | The student |
When an application is received by PCS, what happens? | |
Is PCS in the regular practice of receiving and maintaining applications for admission? | |
What efforts does PCS make to verify the information on the application? | [confirm with Kane] |
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United States v. GHISLAINE MAXWELL, 20 Cr. 330 (AJN)
Does PCS regularly rely on this information to make admissions decisions? | Yes |
Does PCS make admissions decisions in the ordinary course of business? | Yes |
After PCS makes admissions decisions, do these applications remain in their records? | Yes |
Where are they kept? | In the student file – there is no admissions file |
Does PCS make admissions decisions in the ordinary course of business? | Yes |
After PCS makes admissions decisions, do these applications remain in their records? | Yes |
Where are they kept? | In the student file – there is no admissions file |
REVIEW
Question | Answer | Rule
Directing your attention to page 1, what grade is the student applying for? | 12 |
Where did the student attend high school previously? Where is that located? | WPB, Florida |
Why did the student leave? | Moved to New York |
Turning to page 2, Section E, who is listed as the person with financial responsibility for this applicant? | JE | Not offered for truth but for state of mind
Does the applicant expect to apply for financial assistance? | No |
Turning to page 3, Section H, how did the student say she became interested in PCS? | Referred by the president of admissions at Julliard |
Finally, turning to section K, who signed this application? | |
Question | Answer | Rule
Directing your attention to page 1, what grade is the student applying for? | 12 |
Where did the student attend high school previously? Where is that located? | WPB, Florida |
Why did the student leave? | Moved to New York |
Turning to page 2, Section E, who is listed as the person with financial responsibility for this applicant? | JE | Not offered for truth but for state of mind
Does the applicant expect to apply for financial assistance? | No |
Turning to page 3, Section H, how did the student say she became interested in PCS? | Referred by the president of admissions at Julliard |
Finally, turning to section K, who signed this application? | |
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