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637 KB
Extraction Summary
5
People
2
Organizations
0
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
637 KB
Summary
This legal document is a court opinion from case 1:20-cr-00330-AJN, filed on April 16, 2021. The court concludes that perjury charges against the defendant, Maxwell, are legally tenable and can be presented to a jury. However, the court rules that these perjury charges must be severed and tried separately from the Mann Act counts to avoid undue prejudice to the defendant, citing potential issues with admitting evidence of other acts and the risk of disqualifying Maxwell's chosen counsel.
People (5)
| Name | Role | Context |
|---|---|---|
| Maxwell | Defendant |
Mentioned as the defendant whose perjury charges are being discussed for severance from Mann Act counts.
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| Gaudin |
Mentioned in the case citation 'Gaudin, 515 U.S. at 509'.
|
|
| Kross |
Mentioned in the case citation 'Kross, 14 F.3d at 753–54'.
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| Sampson |
Mentioned in the case citation 'United States v. Sampson, 898 F.3d 270, 281 (2d Cir. 2018)'.
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| Walker |
Mentioned in the case citation 'United States v. Walker, 142 F.3d 103, 110 (2d Cir. 1998)'.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government | government agency |
Mentioned as the prosecuting party in the case against Maxwell.
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| The Court | judicial body |
The judicial body making the ruling on severing the perjury charges.
|
Timeline (2 events)
The Court ruled that the perjury charges against Maxwell must be severed and tried separately from the Mann Act counts.
Relationships (1)
The document describes a criminal case where 'The Government' is the prosecuting party and 'Maxwell' is the defendant.
Key Quotes (3)
"invading the ‘inviolable function of the jury’ in our criminal justice system,"Source
— United States v. Sampson (cited by the court)
(Used to explain why courts must guard against resolving certain factual disputes before trial.)
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Quote #1
"defense raises a factual dispute that is inextricably intertwined with a defendant’s potential culpability, a judge cannot resolve that dispute on a Rule 12(b) motion."Source
— United States v. Sampson (cited by the court)
(Quoted from a legal precedent to support the conclusion that the perjury charges are legally tenable for a jury.)
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Quote #2
"solely the adverse effect of being tried for two crimes rather than"Source
— United States v. Walker (cited by the court)
(Used to describe a level of harm to a defendant that is insufficient on its own to warrant severance of charges.)
DOJ-OGR-00020782.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,143 characters)
Case 22-1426, Document 57, 02/28/2023, 3475900, Page164 of 208
A-160
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 23 of 34
A-160
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 23 of 34
civil case, but that is not the legal standard. The Government may prevail if it proves that
Maxwell’s answers could have led to the discovery of other evidence or could influence the
factfinder in the civil case. See Gaudin, 515 U.S. at 509; Kross, 14 F.3d at 753–54. At trial, a
reasonable juror could conclude that truthful answers to the questions may have permitted the
plaintiff to locate other victims or witnesses who could have corroborated the plaintiff’s
testimony. The factual disputes relating to materiality are at least enough to preclude pretrial
resolution. In criminal cases, courts must guard against “invading the ‘inviolable function of the
jury’ in our criminal justice system,” and if the “defense raises a factual dispute that is
inextricably intertwined with a defendant’s potential culpability, a judge cannot resolve that
dispute on a Rule 12(b) motion.” United States v. Sampson, 898 F.3d 270, 281 (2d Cir. 2018).
The Court concludes that the perjury charges are legally tenable and appropriately
presented to the jury.
V. The perjury charges must be severed and tried separately
Although the perjury charges are legally tenable, the Court concludes that the interests of
justice require severing those counts and trying them separately. Trying the perjury counts
together with the Mann Act counts would require admitting evidence of other acts likely to be
unduly prejudicial. It would also risk disqualifying Maxwell’s chosen counsel based on their
involvement in the earlier civil case.
Rule 14(a) of the Federal Rules of Criminal Procedure allows a court to order separate
trials if joining all offenses in a single trial would prejudice the defendant. A defendant seeking
severance must show significant unfairness to outweigh the burden on the court of conducting
multiple trials. United States v. Walker, 142 F.3d 103, 110 (2d Cir. 1998). The harm to the
defendant must be more than “solely the adverse effect of being tried for two crimes rather than
Maxwell’s answers could have led to the discovery of other evidence or could influence the
factfinder in the civil case. See Gaudin, 515 U.S. at 509; Kross, 14 F.3d at 753–54. At trial, a
reasonable juror could conclude that truthful answers to the questions may have permitted the
plaintiff to locate other victims or witnesses who could have corroborated the plaintiff’s
testimony. The factual disputes relating to materiality are at least enough to preclude pretrial
resolution. In criminal cases, courts must guard against “invading the ‘inviolable function of the
jury’ in our criminal justice system,” and if the “defense raises a factual dispute that is
inextricably intertwined with a defendant’s potential culpability, a judge cannot resolve that
dispute on a Rule 12(b) motion.” United States v. Sampson, 898 F.3d 270, 281 (2d Cir. 2018).
The Court concludes that the perjury charges are legally tenable and appropriately
presented to the jury.
V. The perjury charges must be severed and tried separately
Although the perjury charges are legally tenable, the Court concludes that the interests of
justice require severing those counts and trying them separately. Trying the perjury counts
together with the Mann Act counts would require admitting evidence of other acts likely to be
unduly prejudicial. It would also risk disqualifying Maxwell’s chosen counsel based on their
involvement in the earlier civil case.
Rule 14(a) of the Federal Rules of Criminal Procedure allows a court to order separate
trials if joining all offenses in a single trial would prejudice the defendant. A defendant seeking
severance must show significant unfairness to outweigh the burden on the court of conducting
multiple trials. United States v. Walker, 142 F.3d 103, 110 (2d Cir. 1998). The harm to the
defendant must be more than “solely the adverse effect of being tried for two crimes rather than
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DOJ-OGR-00020782
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