DOJ-OGR-00003148.jpg
798 KB
Extraction Summary
6
People
3
Organizations
1
Locations
4
Events
4
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
798 KB
Summary
This legal document is a filing by the Government in response to a defense motion. The Government argues that it is not required to produce pages from a personal diary belonging to a third-party victim because the diary is not in its custody or control. Furthermore, the Government asserts that it has already inquired with the victim, who confirmed that no diary entries exist for the relevant time period in the spring of 1996 when she met the defendant while visiting Epstein.
People (6)
| Name | Role | Context |
|---|---|---|
| defendant | defendant |
The subject of the legal proceedings, whose defense is requesting documents.
|
| civilian third party | victim |
An individual, also referred to as 'this victim', whose personal diary is being requested by the defense. She met Eps...
|
| Epstein |
Mentioned as a person the victim met and visited. The victim's journal entries relate to him. A search warrant was ex...
|
|
| Collins |
Named in the case citation 'United States v. Collins'.
|
|
| Blaszczak |
Named in the case citation 'United States v. Blaszczak'.
|
|
| defense counsel | legal representative |
Mentioned in a footnote as having received a redacted document recovered from one of Epstein's devices.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
The prosecuting party in the case, arguing against the disclosure of a third party's diary.
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| Department of Justice | government agency |
Mentioned in a quote regarding the extent of the Government's 'Brady obligations'.
|
| Executive Branch | government branch |
Mentioned in a quote as a potential part of the government whose materials might fall under 'Brady obligations'.
|
Timeline (4 events)
A victim's first meeting with Epstein, after which she wrote in her journal for about a month.
A trip the victim took months later to visit Epstein, during which she met the defendant.
Execution of a search warrant for one of Epstein's devices.
spring of 1996
The defense is concerned about whether there are diary entries from the spring of 1996.
Locations (1)
| Location | Context |
|---|---|
|
Southern District of New York, mentioned in case citations for 'United States v. Collins' and 'United States v. Blasz...
|
Relationships (4)
The victim had a 'first meeting with Epstein' and took a 'subsequent trip... to visit Epstein'. She also kept journal entries 'relating to Epstein'.
The victim 'met the defendant' during a trip she took to visit Epstein.
The Government is the prosecuting party in a criminal case against the defendant.
The victim 'provided the Government with copies of her journal entries' and 'informed the Government' about the nature of the remaining entries.
Key Quotes (2)
"The Government’s ‘Brady obligations extend only to materials within prosecutors’ possession, custody or control or, in appropriate cases, that of the Department of Justice, perhaps another part of the Executive Branch, or a comparable state authority involved in the federal prosecution."Source
— United States v. Collins case
(Quoted to support the Government's argument that it is not obligated to obtain personal papers of a third party.)
DOJ-OGR-00003148.jpg
Quote #1
"Because this victim stopped writing in her journal about a month after that first meeting with Epstein, there are no entries regarding the subsequent trip she took months later to visit Epstein, during which she met the defendant."Source
— Government (from Dkt. No. 100)
(Quoted from a previous filing to show that the Government has already indicated that no diary entries exist for the period in question.)
DOJ-OGR-00003148.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,435 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 214 of 239
Government has reviewed the full report and confirmed that there is nothing exculpatory contained therein. To the contrary, the report inculpates the defendant. Accordingly, the defendant is not entitled to its immediate disclosure. The Government will produce an unredacted version of this document together with all other witness statements in advance of trial.⁶⁷
Fourth, the defense requests production of pages from a personal diary that is in the custody of a civilian third party and is not in the custody or control of the Government. (Def. Mot. 10 at 10). Leaving aside the fact that the defense cites no authority for the proposition that the Government has an obligation to obtain the personal papers of a third party, see United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019) (“The Government’s ‘Brady obligations extend only to materials within prosecutors’ possession, custody or control or, in appropriate cases, that of the Department of Justice, perhaps another part of the Executive Branch, or a comparable state authority involved in the federal prosecution.’” (quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 742 (S.D.N.Y. 2018))), the Government has already represented that it has asked the third party at issue about the materials the defendant purports to seek and that no such materials exist. In particular, to the extent the defense is concerned with whether there are diary entries from the spring of 1996, the Government has already indicated in response to the defendant’s second bail motion that it is aware of none. (See Dkt. No. 100 at 11 n. 2 (“Because this victim stopped writing in her journal about a month after that first meeting with Epstein, there are no entries regarding the subsequent trip she took months later to visit Epstein, during which she met the defendant. This victim provided the Government with copies of her journal entries relating to Epstein and informed the Government that the remaining entries are personal in nature and have nothing to do with
⁶⁷ As is the case with the other redacted document referenced in this motion, the redacted copy defense counsel attached as Exhibit D was recovered during the execution of a search warrant for one of Epstein’s devices and was produced to defense counsel in the form in which it was recovered from the device.
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DOJ-OGR-00003148
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