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574 KB
Extraction Summary
3
People
2
Organizations
1
Locations
2
Events
1
Relationships
8
Quotes
Document Information
Type:
Legal document
File Size:
574 KB
Summary
This legal document is a court filing arguing that the indictment against Ms. Maxwell is insufficient for her to prepare a defense. The filing claims the indictment uses vague, open-ended time periods for the alleged crimes (e.g., 'from at least in or about 1994') and fails to specifically identify the accusers, referring to them with general terms like 'minor girls' and 'victims'. This vagueness, the document argues, makes it impossible to apply the statute of limitations or know who the government considers a victim.
People (3)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Mentioned as the subject of an Indictment which is argued to be insufficient for her to prepare a defense.
|
| Jain | Party in a legal case |
Mentioned in the case citation United States v. Jain.
|
| Resendiz-Ponce | Party in a legal case |
Mentioned in the case citation United States v. Resendiz-Ponce.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States | Government agency |
Party in the cited legal cases United States v. Jain and United States v. Resendiz-Ponce.
|
| Government | Government agency |
Refers to the prosecuting party that claims there is a "victim".
|
Timeline (2 events)
1994-1997
The Indictment alleges crimes occurred during open-ended time periods, such as "from at least in or about 1994, up to and including at least in or about 1997" and "beginning in at least 1994".
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the citation for United States v. Jain, referring to the Southern District of New York.
|
Relationships (1)
The document describes the Government's Indictment against Ms. Maxwell and her defense's argument that the Indictment is insufficient.
Key Quotes (8)
"When supplemented by discovery material, no additional information is necessary for trial preparation or to prevent surprise."Source
— Court in United States v. Jain
(Cited as a legal precedent regarding pleading deficiencies being cured by discovery.)
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Quote #1
"while an indictment parroting the language of a federal criminal statute is often sufficient, there are crimes that must be charged with greater specificity."Source
— Court in United States v. Resendiz-Ponce
(Cited as legal precedent to argue that the crimes Ms. Maxwell is charged with require more specific details in the indictment.)
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Quote #2
"from at least in or about 1994, up to and including at least in or about 1997"Source
— Indictment
(Quoted as an example of an open-ended time period in the Indictment against Ms. Maxwell.)
DOJ-OGR-00002315(1).jpg
Quote #3
"beginning in at least 1994"Source
— Indictment
(Quoted as another example of an open-ended time period in the Indictment.)
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Quote #4
"minor girls"Source
— Indictment
(Quoted as an example of a vague phrase used in the Indictment to describe the accusers.)
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Quote #5
"victims"Source
— Indictment
(Quoted as an example of a vague phrase used in the Indictment to describe the accusers.)
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Quote #6
"victims were as young as 14"Source
— Indictment
(Quoted as an example of a vague phrase used in the Indictment to describe the accusers.)
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Quote #7
"certain girls were in fact under the age of 18"Source
— Indictment
(Quoted as an example of a vague phrase used in the Indictment to describe the accusers.)
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Quote #8
Full Extracted Text
Complete text extracted from the document (1,617 characters)
Case 1:20-cr-00330-AJN Document 124 Filed 01/25/21 Page 5 of 8
In many cases the bar for sufficiency of an indictment is low. It is also true that courts find, in certain cases, that the discovery provided in connection with the matter may cure various pleading deficiencies. See, e.g., United States v. Jain, No. 19-CR-59 (PKC), 2019 WL 6888635, at *2 (S.D.N.Y. Dec. 18, 2019) (“When supplemented by discovery material, no additional information is necessary for trial preparation or to prevent surprise.”). However, “while an indictment parroting the language of a federal criminal statute is often sufficient, there are crimes that must be charged with greater specificity.” United States v. Resendiz-Ponce, 549 U.S. 102 at 109.
These are those crimes.
Here, neither the Indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare her defense. The Indictment contains multiple open-ended time periods:
- “from at least in or about 1994, up to and including at least in or about 1997” ¶¶ 1, 9, 13, 15; and
- “beginning in at least 1994” ¶ 4.
- “beginning in at least 1994” ¶ 4.
These phrases make the time frame alleged limitless and meaningless for application of the statute of limitations or any defense.
In addition to not identifying the individuals accusing Ms. Maxwell of a crime, the Indictment, through the use of inconsistent and vague phrases, makes it impossible to know who may, or may not, be someone that the Government claims is a “victim.”
- “minor girls” ¶ 1;
- “victims” ¶ 1;
- “victims were as young as 14” ¶ 1;
- “certain girls were in fact under the age of 18” ¶ 1;
- “victims” ¶ 1;
- “victims were as young as 14” ¶ 1;
- “certain girls were in fact under the age of 18” ¶ 1;
2
DOJ-OGR-00002315
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