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754 KB
Extraction Summary
9
People
2
Organizations
4
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
754 KB
Summary
This legal document, part of a court filing, argues against the admissibility of certain evidence in the case against Epstein. It cites multiple legal precedents establishing that proof of lawful conduct on some occasions is irrelevant to disproving a specific criminal charge. The document applies this to the Epstein case, asserting that a prior investigation's findings about his conduct in the 2000s are irrelevant to the current charges from 1994-1997, and notes that two key victims were only interviewed for the first time in late 2019.
People (9)
| Name | Role | Context |
|---|---|---|
| Scarpa | Defendant |
Mentioned in the case citation United States v. Scarpa, 897 F.2d 63, 70 (2d Cir. 1990).
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| Chambers | Defendant |
Mentioned in the case citation United States v. Chambers, 800 F. App’x 43, 46 (2d Cir. 2020).
|
| Walker | Defendant |
Mentioned in the case citation United States v. Walker, 191 F.3d 326, 336 (2d Cir. 1999).
|
| Williams | Defendant |
Mentioned in the case citation United States v. Williams, 205 F.3d 23, 34 (2d Cir. 2000).
|
| Fiumano | Defendant |
Mentioned in the case citation United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356.
|
| Gambino | Defendant |
Mentioned in the case citation United States v. Gambino, 838 F. Supp. 744, 748 (S.D.N.Y. 1993).
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| Epstein | Defendant |
Mentioned as the subject of an investigation and the defendant in the current case.
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| Minor Victim-1 | Victim |
Referenced in the Indictment as a victim who was never interviewed by the USAO-SDFL and first spoke to law enforcemen...
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| Minor Victim-3 | Victim |
Referenced in the Indictment as a victim who was never interviewed by the USAO-SDFL and first spoke to law enforcemen...
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| USAO-SDFL | government agency |
Mentioned as the agency that had never interviewed Minor Victim-1 and Minor Victim-3.
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| this Office | government agency |
Refers to the prosecuting office in the current case, which interviewed Minor Victim-1 and Minor Victim-3 in late Aug...
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Timeline (3 events)
2019-08
Minor Victim-1 and Minor Victim-3 met with and were interviewed by 'this Office' (the prosecuting office).
2019-09
Minor Victim-1 and Minor Victim-3 met with and were interviewed by 'this Office' (the prosecuting office).
Locations (4)
| Location | Context |
|---|---|
|
Mentioned in the context of cocaine importations in the cited case of United States v. Williams.
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|
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Mentioned in a cited case (United States v. Fiumano) regarding a bank robbery.
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|
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Mentioned in a cited case (United States v. Fiumano) regarding a bank robbery.
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Mentioned in a cited case (United States v. Fiumano) regarding a bank robbery.
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Relationships (2)
The document states that Minor Victim-1 is one of the victims referenced in the Indictment against Epstein.
The document states that Minor Victim-3 is one of the victims referenced in the Indictment against Epstein.
Key Quotes (4)
"A defendant may not seek to establish h[er] innocence . . . through proof of the absence of criminal acts on specific occasions."Source
— 2d Cir. Court
(From the ruling in United States v. Scarpa, 897 F.2d 63, 70 (2d Cir. 1990).)
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Quote #1
"A single occurrence of lawful conduct is ‘simply irrelevant’ to other occurrences of lawful conduct."Source
— 2d Cir. Court
(From the ruling in United States v. Chambers, 800 F. App’x 43, 46 (2d Cir. 2020), quoting United States v. Walker.)
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Quote #2
"We reject Williams’s assertion that the evidence of innocent travel was necessary to rebut the government’s allegation that Williams had been involved in other cocaine importations from Jamaica. Although the government did argue that Williams had been involved in other importations, it did not allege that Williams had engaged in drug activity during these particular trips."Source
— 2d Cir. Court
(From the ruling in United States v. Williams, 205 F.3d 23, 34 (2d Cir. 2000).)
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Quote #3
"The principle is rather elementary. A defendant charged with robbing a bank in Manhattan on April 22 cannot offer as evidence to disprove the charged crime that he did not rob the bank’s branches in Brooklyn or the Bronx on April 22 or that he did not rob the Manhattan branch on April 20, 21, 23, and 24, because this evidence is irrelevant to the charge that he robbed the Manhattan bank on April 22."Source
— S.D.N.Y. Court
(From the ruling in United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356, at *7 (S.D.N.Y. Apr. 25, 2016).)
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,205 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 75 of 239
crimes or events. See, e.g., United States v. Scarpa, 897 F.2d 63, 70 (2d Cir. 1990) (“A defendant
may not seek to establish h[er] innocence . . . through proof of the absence of criminal acts on
specific occasions.”); United States v. Chambers, 800 F. App’x 43, 46 (2d Cir. 2020) (“A single
occurrence of lawful conduct is ‘simply irrelevant’ to other occurrences of lawful conduct.”
(quoting United States v. Walker, 191 F.3d 326, 336 (2d Cir. 1999))); United States v. Williams,
205 F.3d 23, 34 (2d Cir. 2000) (“We reject Williams’s assertion that the evidence of innocent
travel was necessary to rebut the government’s allegation that Williams had been involved in other
cocaine importations from Jamaica. Although the government did argue that Williams had been
involved in other importations, it did not allege that Williams had engaged in drug activity during
these particular trips.”); United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356, at
*7 (S.D.N.Y. Apr. 25, 2016) (“The principle is rather elementary. A defendant charged with
robbing a bank in Manhattan on April 22 cannot offer as evidence to disprove the charged crime
that he did not rob the bank’s branches in Brooklyn or the Bronx on April 22 or that he did not rob
the Manhattan branch on April 20, 21, 23, and 24, because this evidence is irrelevant to the charge
that he robbed the Manhattan bank on April 22.”); United States v. Gambino, 838 F. Supp. 744,
748 (S.D.N.Y. 1993).
Inadmissibility aside, the Indictment specifically charges conduct between 1994 and 1997.
That a different investigative team focused on Epstein’s conduct in the early 2000s may not have
uncovered evidence about the defendant’s conduct in the 1990s has no bearing on the charges in
this case, which was brought entirely independent of the prior SDFL investigation. Moreover, and
as detailed further below, two of the victims referenced in the Indictment, Minor Victim-1 and
Minor Victim-3, were never interviewed by the USAO-SDFL, and had never spoken to law
enforcement until they met with this Office in late August and September 2019, after Epstein’s
may not seek to establish h[er] innocence . . . through proof of the absence of criminal acts on
specific occasions.”); United States v. Chambers, 800 F. App’x 43, 46 (2d Cir. 2020) (“A single
occurrence of lawful conduct is ‘simply irrelevant’ to other occurrences of lawful conduct.”
(quoting United States v. Walker, 191 F.3d 326, 336 (2d Cir. 1999))); United States v. Williams,
205 F.3d 23, 34 (2d Cir. 2000) (“We reject Williams’s assertion that the evidence of innocent
travel was necessary to rebut the government’s allegation that Williams had been involved in other
cocaine importations from Jamaica. Although the government did argue that Williams had been
involved in other importations, it did not allege that Williams had engaged in drug activity during
these particular trips.”); United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356, at
*7 (S.D.N.Y. Apr. 25, 2016) (“The principle is rather elementary. A defendant charged with
robbing a bank in Manhattan on April 22 cannot offer as evidence to disprove the charged crime
that he did not rob the bank’s branches in Brooklyn or the Bronx on April 22 or that he did not rob
the Manhattan branch on April 20, 21, 23, and 24, because this evidence is irrelevant to the charge
that he robbed the Manhattan bank on April 22.”); United States v. Gambino, 838 F. Supp. 744,
748 (S.D.N.Y. 1993).
Inadmissibility aside, the Indictment specifically charges conduct between 1994 and 1997.
That a different investigative team focused on Epstein’s conduct in the early 2000s may not have
uncovered evidence about the defendant’s conduct in the 1990s has no bearing on the charges in
this case, which was brought entirely independent of the prior SDFL investigation. Moreover, and
as detailed further below, two of the victims referenced in the Indictment, Minor Victim-1 and
Minor Victim-3, were never interviewed by the USAO-SDFL, and had never spoken to law
enforcement until they met with this Office in late August and September 2019, after Epstein’s
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