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646 KB
Extraction Summary
3
People
1
Organizations
0
Locations
3
Events
1
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
646 KB
Summary
This legal document is a court filing arguing against several defense motions. The prosecution contends that evidence of the defendant's lifestyle and close partnership with Jeffrey Epstein is relevant to the conspiracy charge and not prejudicial. The filing also argues that trial participants should not be precluded from using the terms "Victims" or "rape" when referring to the Minor Victims and acts committed by Epstein.
People (3)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Alleged perpetrator |
Mentioned in relation to his properties, private jet, employees, a rape he allegedly committed against a Minor Victim...
|
| The Defendant | Defendant |
The subject of the legal filing, who is moving to preclude certain testimony and references. Her relationship with Ep...
|
| Minor Victims | Victims |
A group of individuals whom the defense wants to prevent from being referred to as "Victims" at trial. One is mention...
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| The Court | Judicial body |
The entity being asked to deny the defense's motions.
|
Timeline (3 events)
2004
The alleged conspiracy for which the relationship between Epstein and the defendant in 2004 and 2005 is considered relevant evidence.
A rape committed by Jeffrey Epstein against one of the Minor Victims.
Relationships (1)
The document states there is evidence showing they were "extremely close partners in 2005," which makes it more probable they had "such a relationship in 2004, during the time period of the conspiracy."
Key Quotes (1)
"see nothing, hear nothing, say nothing."Source
— Unnamed (instruction to employees)
(Quoted from exhibit GX 606 at 4, described as an instruction to employees, which is argued to be relevant and not hearsay.)
DOJ-OGR-00005860.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (1,873 characters)
Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 77 of 84
consistent with the rules in this exhibit.19 The relevance of the document is self-evident: among
other things, it directs employees to “see nothing, hear nothing, say nothing.” (GX 606 at 4). It is
not prejudicial as to her “lifestyle” (Def. Mot. 13 at 3), because the jury will already hear testimony
about her and Epstein’s various properties, private jet, and employees. And the document is not
hearsay, because the statements are being offered as instructions to staff, not for the truth of the
matter asserted.
other things, it directs employees to “see nothing, hear nothing, say nothing.” (GX 606 at 4). It is
not prejudicial as to her “lifestyle” (Def. Mot. 13 at 3), because the jury will already hear testimony
about her and Epstein’s various properties, private jet, and employees. And the document is not
hearsay, because the statements are being offered as instructions to staff, not for the truth of the
matter asserted.
As described above, each of these exhibits is highly relevant, not hearsay or subject to a
hearsay exception, and can be authenticated at trial. The Court should deny the defense’s motion
regarding relevance and Rule 403, and deny the motion regarding authentication with leave to
renew it at trial.
hearsay exception, and can be authenticated at trial. The Court should deny the defense’s motion
regarding relevance and Rule 403, and deny the motion regarding authentication with leave to
renew it at trial.
VII. There is No Basis to Preclude Discussion of “Victims” or Rape
Citing no case in the federal system, the defendant moves to preclude any trial participants
from referring to the Minor Victims as Victims. The defendant also moves to preclude testimony
concerning a rape committed by Jeffrey Epstein against one of the Minor Victims. Both of these
motions lack merit, and they should be denied.
from referring to the Minor Victims as Victims. The defendant also moves to preclude testimony
concerning a rape committed by Jeffrey Epstein against one of the Minor Victims. Both of these
motions lack merit, and they should be denied.
A. References to Victims
19 Here and elsewhere (see, e.g. Def. Mot. 2 at 3-4), the defense argues that evidence that post-
dates the time period of the conspiracy is irrelevant. That is incorrect. What matters is whether
the evidence tends to make a fact of consequence more or less probable. If, for instance, there is
evidence showing that Epstein and the defendant were extremely close partners in 2005, that tends
to make it more probable that they had such a relationship in 2004, during the time period of the
conspiracy. It is therefore highly relevant.
dates the time period of the conspiracy is irrelevant. That is incorrect. What matters is whether
the evidence tends to make a fact of consequence more or less probable. If, for instance, there is
evidence showing that Epstein and the defendant were extremely close partners in 2005, that tends
to make it more probable that they had such a relationship in 2004, during the time period of the
conspiracy. It is therefore highly relevant.
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DOJ-OGR-00005860
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