EFTA00014982.pdf
111 KB
Extraction Summary
5
People
2
Organizations
3
Locations
3
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / letter
File Size:
111 KB
Summary
Legal correspondence from Ghislaine Maxwell's defense attorney, Jeffrey Pagliuca, to the US Attorney's Office regarding objections to hearsay statements. The defense objects to statements made by Epstein to employees (specifically CC-1) about Maxwell 'finding girls' and instructions regarding computer removal, arguing these occurred post-conspiracy and constitute 'idle chatter' rather than furtherance of a conspiracy. The letter also addresses the scope of 'minor victims' referenced in the indictment versus those in Florida investigations.
People (5)
| Name | Role | Context |
|---|---|---|
| Jeffrey S. Pagliuca | Defense Attorney |
Author of the letter representing Ghislaine Maxwell.
|
| Ghislaine Maxwell | Defendant |
Subject of the criminal case 20 Cr. 330 (AJN).
|
| Jeffrey Epstein | Deceased / Co-conspirator |
Cited as making hearsay statements to employees and victims.
|
| CC-1 | Co-conspirator / Employee |
Recipient of statements from Epstein regarding Maxwell finding girls; received direction to help remove computers.
|
| CC-2 | Co-conspirator |
Gave direction alongside Epstein to CC-1 to help take computers; made statements to families of victims.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan and Foreman, P.C |
Law firm representing Ghislaine Maxwell.
|
|
| United States Attorney's Office |
Recipient of the letter; Southern District of New York.
|
Locations (3)
| Location | Context |
|---|---|
|
Location of Haddon, Morgan and Foreman, P.C.
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|
|
Location of US Attorney's Office SDNY.
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|
|
Referenced in relation to state and federal investigations involving minor victims.
|
Relationships (3)
Epstein statement that Maxwell 'used to find girls for him'.
Statements categorized under 'Statements made by Jeffrey Epstein to his employees'.
Jointly gave direction to CC-1 to help take computers.
Key Quotes (4)
"The first exemplar is a statement allegedly from Epstein to CC-1 claiming that Ms. Maxwell 'used to find girls for him.'"Source
EFTA00014982.pdf
Quote #1
"direction from Epstein and CC-2 to CC-1 to 'help someone who was coming to take the computers....'"Source
EFTA00014982.pdf
Quote #2
"Statements made by Epstein to friends and Family of Minor Victims"Source
EFTA00014982.pdf
Quote #3
"Statements made by CC-2 to friends and Family of Minor Victims"Source
EFTA00014982.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (2,928 characters)
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
Jeffrey S. Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
H A D D O N
M O R G A N
F O R E M A N
M O R G A N
F O R E M A N
November 8, 2021
VIA EMAIL
[REDACTED]
United States Attorney’s Office
Southern District of New York
1 St. Andrew’s Plaza
New York, NY 10007
United States Attorney’s Office
Southern District of New York
1 St. Andrew’s Plaza
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Defendant’s Good Faith, Non-Frivolous Objections to Proffered Co-Conspirator
Hearsay Statements
Defendant’s Good Faith, Non-Frivolous Objections to Proffered Co-Conspirator
Hearsay Statements
Dear Counsel,
Pursuant to the Court’s November 1, 2021 Order we write to note our good faith
objections to certain categories of alleged co-conspirator hearsay statements, and representative
examples:
objections to certain categories of alleged co-conspirator hearsay statements, and representative
examples:
Regarding the first, third, and fourth¹ designated categories, there are two issues for
conferral. First, we assume that these proffered statements are limited to those individuals
specifically identified by the government as “minor victims” in the indictment or correspondence
to defense counsel dated October 11, 2021. There were many alleged minor victims in the
Southern Florida state and federal investigations. To the extent that the government intends to
include statements made to other alleged “minor victims” not specifically identified, Ms.
conferral. First, we assume that these proffered statements are limited to those individuals
specifically identified by the government as “minor victims” in the indictment or correspondence
to defense counsel dated October 11, 2021. There were many alleged minor victims in the
Southern Florida state and federal investigations. To the extent that the government intends to
include statements made to other alleged “minor victims” not specifically identified, Ms.
___________________
¹ “Statements made by Epstein to friends and Family of Minor Victims,” “Statements
made by CC-2 to friends and Family of Minor Victims,” and “Statements made by Jeffrey
Epstein to the Minor Victims or in their presence.”
¹ “Statements made by Epstein to friends and Family of Minor Victims,” “Statements
made by CC-2 to friends and Family of Minor Victims,” and “Statements made by Jeffrey
Epstein to the Minor Victims or in their presence.”
[Page 2]
November 8, 2021
Page 2
Page 2
Maxwell objects. In addition, these categories do not contain any temporal limitations and we
object to any statements allegedly made outside the dates of the alleged conspiracy.
object to any statements allegedly made outside the dates of the alleged conspiracy.
Category 2, “Statements made by Jeffrey Epstein to his employees” appears to, primarily,
relate to statements that post-date any alleged conspiracy. The first exemplar is a statement
allegedly from Epstein to CC-1 claiming that Ms. Maxwell “used to find girls for him.” This
statement, or statements like it, cannot have been made either in the course of or in furtherance
of any conspiracy at issue here and are no more than “idle chatter.” United States v. Lieberman,
637 F.2d 95, 102 (2d Cir.1980) (challenged testimony “smack[ed] of nothing more than casual
conversation about past events. It is difficult to envision how it would have furthered the
conspiracy”). Similarly, the second example concerns direction from Epstein and CC-2 to CC-1
to “help someone who was coming to take the computers....” Again, this statement does not
appear to be during or in furtherance of any conspiracy alleged in the indictment. See Lutwak v.
United States, 344 U.S. 604 (1953); Krulewitch v. United States, 336 U.S. 440 (1949). We
assume the third example relates to the time period alleged in the indictment. To the extent it
does not we object.
relate to statements that post-date any alleged conspiracy. The first exemplar is a statement
allegedly from Epstein to CC-1 claiming that Ms. Maxwell “used to find girls for him.” This
statement, or statements like it, cannot have been made either in the course of or in furtherance
of any conspiracy at issue here and are no more than “idle chatter.” United States v. Lieberman,
637 F.2d 95, 102 (2d Cir.1980) (challenged testimony “smack[ed] of nothing more than casual
conversation about past events. It is difficult to envision how it would have furthered the
conspiracy”). Similarly, the second example concerns direction from Epstein and CC-2 to CC-1
to “help someone who was coming to take the computers....” Again, this statement does not
appear to be during or in furtherance of any conspiracy alleged in the indictment. See Lutwak v.
United States, 344 U.S. 604 (1953); Krulewitch v. United States, 336 U.S. 440 (1949). We
assume the third example relates to the time period alleged in the indictment. To the extent it
does not we object.
Best Regards,
[Signature]
Jeffrey S. Pagliuca
EFTA00014982
EFTA00014983
EFTA00014983
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