DOJ-OGR-00002008.jpg

769 KB

Extraction Summary

3
People
3
Organizations
1
Locations
5
Events
1
Relationships
4
Quotes

Document Information

Type: Legal document
File Size: 769 KB
Summary

This legal document is a filing by the defense for Ms. Maxwell, arguing that the discovery evidence provided by the government fails to corroborate the allegations against her. The defense claims that despite the government's initial assertions at a bail hearing, the vast majority of the documents produced are from a time period well after the alleged conspiracy (1994-1997) and contain no meaningful corroboration.

People (3)

Name Role Context
Ms. Maxwell Defendant
Mentioned throughout as the subject of the government's allegations and the defendant in the case.
Ghislaine Maxwell British socialite
Mentioned in the title of a Daily Mail article cited in a footnote, in the context of a French probe.
Jeffrey Epstein
Mentioned in a footnote in the title of a Daily Mail article about a French probe and as the owner of residences from...

Organizations (3)

Name Type Context
government government agency
Referred to as the prosecuting party in the case against Ms. Maxwell.
Court government agency
Referred to as the judicial body presiding over the bail hearing and the case.
Daily Mail company
Cited as the source of an article in a footnote.

Timeline (5 events)

1994-1997
The time period of the conspiracy charged in the indictment against Ms. Maxwell.
2019-01-01
Searches of Jeffrey Epstein's residences where documents and images were seized from electronic devices.
Epstein's residences
2020-11-09
Production of over 1.2 million documents by the government to the defense.
government defense
2020-11-18
Production of over 1.2 million documents by the government to the defense.
government defense
Initial bail hearing where the government represented that its evidence was strong and corroborated.
government Court defense

Locations (1)

Location Context
Mentioned in the title of a Daily Mail article about a probe into Jeffrey Epstein.

Relationships (1)

Ms. Maxwell professional Jeffrey Epstein
The document implies a connection through the charged conspiracy and a French probe mentioned in a Daily Mail article looking into her involvement in his offending. Documents were also seized from Epstein's residences for her case.

Key Quotes (4)

"the evidence in this case is strong"
Source
— government (A representation made by the government to the Court at the initial bail hearing.)
DOJ-OGR-00002008.jpg
Quote #1
"backed up [by] contemporaneous documents . . . [including] flight records, diary entries, business records, and other evidence."
Source
— government (A representation made by the government about the allegations of the alleged victims.)
DOJ-OGR-00002008.jpg
Quote #2
"corroborated by significant contemporaneous documentary evidence."
Source
— government (The government's proffer to the Court that witness testimony would be supported by evidence.)
DOJ-OGR-00002008.jpg
Quote #3
"French prosecutors probing Jeffrey Epstein over rape and abuse of children in Paris widen probe to include Ghislaine Maxwell to see if British socialite was involved in his offending,"
Source
— Daily Mail (Title of an article cited in a footnote.)
DOJ-OGR-00002008.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (2,310 characters)

Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 36 of 45
E. The Discovery Contains No Meaningful Documentary Corroboration of the Government’s Allegations Against Ms. Maxwell
At the initial bail hearing, the government represented to the Court that “the evidence in this case is strong” and that the allegations of the alleged victims were “backed up [by] contemporaneous documents . . . [including] flight records, diary entries, business records, and other evidence.” (Dkt. 4 at 5.) The Court credited those representations and accepted the government’s proffer that the witness testimony would be “corroborated by significant contemporaneous documentary evidence.” (Tr. 82) (emphasis added). The defense, of course, could not rebut the government’s representations at the hearing because the government had not yet produced discovery.
Since then, the government has produced, and the defense has reviewed, hundreds of thousands of pages of discovery, including the entire initial tranche of discovery that the government represented was the core of its case against Ms. Maxwell.⁹ The discovery contains no meaningful documentary corroboration of the allegations whatsoever, much less “significant” corroboration that the Court was led to believe existed. The vast majority of the discovery that the defense has reviewed relates to the time period in the 2000s and the 2010s, well after the conspiracy charged in the indictment (1994–1997). These documents include [REDACTED]
[REDACTED]
[REDACTED] In fact, only
[REDACTED]
Daily Mail, “French prosecutors probing Jeffrey Epstein over rape and abuse of children in Paris widen probe to include Ghislaine Maxwell to see if British socialite was involved in his offending,” (Oct. 25, 2020), https://www.dailymail.co.uk/news/article-8878825/French-prosecutors-probing-Jeffrey-Epstein-widen-probe-include-Ghislaine-Maxwell.html.
⁹ The defense has not yet completed its review of the over 1.2 million documents produced on November 9, 2020 and November 18, 2020. This production includes documents and images seized from electronic devices found at Epstein’s residences in searches of his residences in 2019. Our initial review, however, shows that the documents are from the 2000s and 2010s, well after the charged conspiracy.
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DOJ-OGR-00002008

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