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736 KB
Extraction Summary
3
People
2
Organizations
0
Locations
3
Events
1
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
736 KB
Summary
This legal document, filed on January 25, 2021, presents an argument from Ms. Maxwell's defense. The defense argues against the joinder of Perjury Counts with Mann Act Counts, asserting it would create a substantial risk of jury confusion and prejudice Ms. Maxwell. The document also accuses the government of strategically limiting the charges to the 1994-1997 period to avoid the legal implications of Epstein's 2007 Non-Prosecution Agreement, while simultaneously trying to introduce conduct from a later period.
People (3)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Subject of the legal arguments, referred to as the individual who would be prejudiced by the joinder of Perjury and M...
|
| Epstein |
Mentioned in relation to his 2007 Non-Prosecution Agreement (“NPA”), which the government is trying to avoid impactin...
|
|
| Ramos |
Cited in a legal precedent (Ramos, 2009 WL 1619912) regarding the severing of drug counts to avoid jury confusion.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| government | government agency |
The prosecuting party in the case against Ms. Maxwell, accused of strategically framing charges to avoid legal challe...
|
| defense | legal team |
Mentioned in a footnote as disputing the government's interpretation of the Non-Prosecution Agreement.
|
Timeline (3 events)
1994-1997
The government chose to allege violations by Ms. Maxwell only within this narrow time period.
Relationships (1)
The document discusses how Epstein's 2007 Non-Prosecution Agreement is relevant to the government's prosecution of Ms. Maxwell, indicating a connection between their legal cases.
Key Quotes (2)
"was limited by its terms to conduct spanning from 2001 to 2007, a time period that post-dates the conduct charged in the Indictment."Source
— government
(The government's argument regarding the scope of Epstein's 2007 Non-Prosecution Agreement.)
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Quote #1
"severing “temporally distinct” drug counts involving a different controlled substance from other drug counts because of “the potential for jury confusion, or improper propensity inferences, with respect to the drug-related aspects of the original charges”"Source
— Ramos, 2009 WL 1619912, at *2
(A legal citation used to support the argument that joining different counts could confuse a jury.)
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Quote #2
Full Extracted Text
Complete text extracted from the document (2,192 characters)
Case 1:20-cr-00330-AJN Document 120 Filed 01/25/21 Page 15 of 19
jury would convict Ms. Maxwell on the Mann Act Counts based on a false inference of criminal
propensity. Similarly, it would create a substantial risk that the jury will confuse the legal and
factual issues pertinent to the Perjury Counts and convict Ms. Maxwell without independently
considering those counts. See Ramos, 2009 WL 1619912, at *2 (severing “temporally distinct”
drug counts involving a different controlled substance from other drug counts because of “the
potential for jury confusion, or improper propensity inferences, with respect to the drug-related
aspects of the original charges”).
propensity. Similarly, it would create a substantial risk that the jury will confuse the legal and
factual issues pertinent to the Perjury Counts and convict Ms. Maxwell without independently
considering those counts. See Ramos, 2009 WL 1619912, at *2 (severing “temporally distinct”
drug counts involving a different controlled substance from other drug counts because of “the
potential for jury confusion, or improper propensity inferences, with respect to the drug-related
aspects of the original charges”).
Furthermore, the government’s decision to allege violations only in the narrow 1994-
1997 time period was deliberate—it did so, in part, to try to avoid the impact of Epstein’s 2007
Non-Prosecution Agreement (“NPA”). In its opposition to Ms. Maxwell’s initial bail
application, the government argued that the NPA did not protect Ms. Maxwell from prosecution
principally because the Indictment did not charge conduct covered by the NPA, which the
government argues “was limited by its terms to conduct spanning from 2001 to 2007, a time
period that post-dates the conduct charged in the Indictment.” (Dkt. 22 at 5-6).² The
government now wants it both ways. It has confined the allegations in the Indictment to the
earlier time frame to try to prevent a legal challenge that would result in the dismissal of the
Mann Act Counts, but at the same time it seeks to introduce conduct from the later time period
by joining the Perjury Counts. The government should not be permitted to do so.
1997 time period was deliberate—it did so, in part, to try to avoid the impact of Epstein’s 2007
Non-Prosecution Agreement (“NPA”). In its opposition to Ms. Maxwell’s initial bail
application, the government argued that the NPA did not protect Ms. Maxwell from prosecution
principally because the Indictment did not charge conduct covered by the NPA, which the
government argues “was limited by its terms to conduct spanning from 2001 to 2007, a time
period that post-dates the conduct charged in the Indictment.” (Dkt. 22 at 5-6).² The
government now wants it both ways. It has confined the allegations in the Indictment to the
earlier time frame to try to prevent a legal challenge that would result in the dismissal of the
Mann Act Counts, but at the same time it seeks to introduce conduct from the later time period
by joining the Perjury Counts. The government should not be permitted to do so.
In addition, joinder of the Perjury Counts would prejudice Ms. Maxwell because it could
impact the ability of Ms. Maxwell’s counsel of choice to participate in the criminal trial. The
Perjury Counts will involve complicated legal issues about permissible deposition questions,
whether the answers to the poorly formulated questions would have been allowed, the role of a
impact the ability of Ms. Maxwell’s counsel of choice to participate in the criminal trial. The
Perjury Counts will involve complicated legal issues about permissible deposition questions,
whether the answers to the poorly formulated questions would have been allowed, the role of a
² The defense disputes that the coverage of the NPA is so limited. See Motion to Dismiss
Indictment for Breach of Non-Prosecution Agreement.
Indictment for Breach of Non-Prosecution Agreement.
11
DOJ-OGR-00002293
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