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664 KB
Extraction Summary
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People
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Organizations
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Locations
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Events
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Relationships
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Quotes
Document Information
Type:
Legal document
File Size:
664 KB
Summary
This legal document, part of a court filing, outlines the Government's strategy for an upcoming trial. The prosecution anticipates defense attacks on the credibility of 'Minor Victims' and plans to introduce prior consistent statements to rebut these attacks and rehabilitate its witnesses. Additionally, the Government argues to preclude the defense from introducing what it deems irrelevant and prejudicial evidence, specifically concerning the history and outcomes of various 'Epstein investigations' in other jurisdictions.
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Refers to the prosecution in the case, which is anticipating defense attacks and making motions to the court.
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| Court | government agency |
The judicial body presiding over the trial. The Government will raise issues with the Court, and motions are aimed at...
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| 2d Cir. | government agency |
Abbreviation for the United States Court of Appeals for the Second Circuit, mentioned in a case citation.
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Timeline (2 events)
A trial where a jury will be asked to determine if the defendant conspired to arrange the sexual abuse of six specific minors.
Relationships (2)
The document outlines the Government's legal strategy in anticipation of 'defense attacks' and its motions to preclude the defense from making certain arguments.
defendant
→
criminal allegation
→
six specific minors
The document states the jury will be asked to determine if the defendant conspired with others to arrange for the sexual abuse of the minors.
Key Quotes (2)
"recently fabricated [their testimony] or acted from a recent improper influence or motive,"Source
— unspecified declarant
(A charge the Government expects the defense to make, which the Government will rebut with prior consistent statements under Fed. R. Evid. 801(d)(1)(B)(i).)
DOJ-OGR-00005577.jpg
Quote #1
"rehabilitate the declarant’s credibility as a witness,"Source
— Government
(The purpose for which the Government will offer prior consistent statements, in response to charges of inconsistent statements or faulty memory.)
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Quote #2
Full Extracted Text
Complete text extracted from the document (1,919 characters)
Case 1:20-cr-00330-PAE Document 383 Filed 10/29/21 Page 23 of 40
Government need not wait until the witness is cross-examined. See United States v. Flores, 945 F.3d 687, 706 (2d Cir. 2019).
Following defense attacks on the Minor Victims’ credibility, the Government anticipates offering prior consistent statements it expects to elicit from its witnesses. Specifically, while the Government expects that some of its prior consistent statements will be offered to rebut the charge that the declarant “recently fabricated [their testimony] or acted from a recent improper influence or motive,” Fed. R. Evid. 801(d)(1)(B)(i), many other statements will be offered to “rehabilitate the declarant’s credibility as a witness,” including from charges that the declarant has given inconsistent statements or has a faulty memory, Fed. R. Evid. 801(d)(1)(B)(ii). Because the grounds for admission will depend on the defense’s precise challenge to the witness, the Government will raise this issue with the Court before eliciting prior consistent statements from its witnesses.
III. The Court Should Preclude the Defense from Making Improper Arguments and Proffering Irrelevant Evidence
At trial, the jury will be asked to determine whether the defendant conspired with others to arrange for the sexual abuse of six specific minors. Several of the Government’s motions are aimed at preventing the defense from surprising the Court and the Government with irrelevant, inflammatory, and highly prejudicial arguments.
The defense response makes clear that they intend to put before the jury the history of the various Epstein investigations in other jurisdictions and the outcomes of those matters. Although that evidence is entirely improper and irrelevant, the defense plainly intends to make this central to the trial. (See Def. Opp. at 28-29). The breadth of the conspiracy theories the defense intends
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