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DOJ-OGR-00005708.jpg

738 KB

Extraction Summary

2
People
3
Organizations
0
Locations
2
Events
2
Relationships
6
Quotes

Document Information

Type: Legal document
File Size: 738 KB
Summary

This legal document, filed on October 29, 2021, presents an argument against introducing evidence of alleged false statements (perjury counts) in Ms. Maxwell's trial. The filing contends that such evidence would substantially prejudice the jury by introducing unrelated allegations, risk the disqualification of her counsel, and create a distracting side-show, thereby jeopardizing her Sixth Amendment right to a fair trial. The arguments heavily rely on the Court's reasoning from a prior severance ruling.

People (2)

Name Role Context
Ms. Maxwell Defendant
Mentioned throughout the document as the subject of the legal arguments regarding her right to a fair trial and the p...
Epstein
Mentioned in the context of civil litigation against him, which is described as remote from Ms. Maxwell's charged con...

Organizations (3)

Name Type Context
Court government agency
Referenced as the judicial body that made a prior severance ruling and is being addressed in this filing.
government government agency
Mentioned as the party that would potentially introduce allegedly false deposition statements at trial.
DOJ-OGR government agency
Appears in the footer of the document (DOJ-OGR-00005708), likely indicating the Department of Justice.

Timeline (2 events)

A legal argument is being made to prevent the introduction of evidence of alleged false statements (perjury counts) in Ms. Maxwell's trial.
Ms. Maxwell the Court the government
The document references a prior "severance ruling" made by the Court.
the Court

Relationships (2)

Ms. Maxwell associates Epstein
The document mentions civil litigation against Epstein in the context of evidence that could be introduced in Ms. Maxwell's trial, suggesting a connection relevant to the legal proceedings.
Ms. Maxwell professional Maxwell's attorneys
The document discusses the potential disqualification of one of Maxwell's attorneys, confirming a client-attorney relationship.

Key Quotes (6)

"conceal"
Source
— Unknown (attributed to a purported effort) (Used to describe a purported effort to hide other crimes, which would be evidenced by alleged false statements.)
DOJ-OGR-00005708.jpg
Quote #1
"would introduce unrelated allegations of sexual abuse, which would potentially expose the jury to evidence that might otherwise not be admissible . . . [and] to a wider swath of information regarding civil litigation against Epstein that is remote from Maxwell’s charged conduct."
Source
— The Court (from a prior ruling) (Quoted from a prior court ruling (Id. at 24) to argue against allowing evidence related to perjury counts.)
DOJ-OGR-00005708.jpg
Quote #2
"a significant risk that the jury will cumulate the evidence of the various crimes charged and find guilt when, if considered separately, it would not do so."
Source
— The Court (from a prior ruling) (Quoted from a prior court ruling (Id.) to highlight the risk of prejudice if the jury hears evidence on the perjury counts.)
DOJ-OGR-00005708.jpg
Quote #3
"likely to require disqualification of at least one of Maxwell’s attorneys from participating as an advocate on her behalf,"
Source
— The Court (from a prior ruling) (Quoted from a prior court ruling (Id. at 24-25) to argue that introducing the evidence could lead to the disqualification of Maxwell's counsel.)
DOJ-OGR-00005708.jpg
Quote #4
"implicate[] [Ms.] Maxwell’s Sixth Amendment right to be represented by the counsel of her choice"
Source
— The Court (from a prior ruling) (Quoted from a prior court ruling (Id. at 24-25) to explain how disqualifying an attorney would violate Maxwell's constitutional rights.)
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Quote #5
"narrower issues"
Source
— The Court (from a prior ruling) (Used to describe the proper focus of the trial, from which the perjury charges would be a distraction.)
DOJ-OGR-00005708.jpg
Quote #6

Full Extracted Text

Complete text extracted from the document (2,201 characters)

Case 1:20-cr-00330-PAE Document 389 Filed 10/29/21 Page 7 of 11
Second, any evidence of alleged false statements, whether it is introduced as direct evidence of the perjury counts or as evidence of a purported effort to “conceal” the other crimes charged in the superseding indictment, would substantially prejudice Ms. Maxwell and would jeopardize her right to a fair trial for the same reasons the Court identified in its severance ruling. Allowing the jury to consider evidence related to the perjury counts “would introduce unrelated allegations of sexual abuse, which would potentially expose the jury to evidence that might otherwise not be admissible . . . [and] to a wider swath of information regarding civil litigation against Epstein that is remote from Maxwell’s charged conduct.” Id. at 24. This would present “a significant risk that the jury will cumulate the evidence of the various crimes charged and find guilt when, if considered separately, it would not do so.” Id. Further, allowing the introduction of this evidence would “likely to require disqualification of at least one of Maxwell’s attorneys from participating as an advocate on her behalf,” which would “implicate[] [Ms.] Maxwell’s Sixth Amendment right to be represented by the counsel of her choice” and would significantly prejudice her right to a fair trial. Id. at 24-25. Introducing evidence related to the perjury counts as evidence of alleged concealment, or for any purpose, would present these same problems and should not be allowed.
Third, as the Court recognized in its prior ruling, fully litigating the perjury charges— which would be necessary if the government were allowed to introduce the allegedly false deposition statements to show concealment—would result in a distracting and time-intensive side-show at trial that will confuse the jury with legal and factual issues that are far afield from the “narrower issues” that pertain to the other charged offenses. Id. at 25-26. This would frustrate the goal of a fair and efficient trial on the remaining charges. Id. at 26. For the same reasons, whatever probative value (if any) this evidence may have related to the other charged
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DOJ-OGR-00005708

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