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693 KB
Extraction Summary
6
People
3
Organizations
1
Locations
2
Events
4
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
693 KB
Summary
This legal document, filed on December 15, 2021, is a motion from the prosecution arguing against allowing testimony from an individual named Scarola. The prosecution contends that Scarola's proposed testimony regarding another witness, Carolyn, is irrelevant and non-impeaching, as the information has already been obtained from Carolyn directly. The document also details over $3.2 million in compensation Carolyn received from claims related to Epstein and Sarah Kellen, and discusses a 2020 meeting where Scarola showed Carolyn a picture of an Epstein associate.
People (6)
| Name | Role | Context |
|---|---|---|
| Scarola |
A person the defendant proposes to have testify. Was present for Carolyn's meetings with the Government and is a memb...
|
|
| Carolyn | Witness/Victim |
A key witness who received compensation from the Epstein Victims Compensation Program and is testifying against Ms. M...
|
| Epstein |
Mentioned in relation to claims made by Carolyn and as having an associate in a picture.
|
|
| Sarah Kellen |
Mentioned in relation to claims made by Carolyn.
|
|
| Ms. Maxwell | Defendant |
The defendant in the case, against whom Carolyn is testifying.
|
| Jane | Epstein associate |
The name of an Epstein associate in a picture shown to Carolyn.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Epstein Victims Compensation Program | compensation fund |
Paid $2,804,000 to Carolyn.
|
| Government | government agency |
The prosecution in the case. Met with Carolyn and Scarola.
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| Florida bar | professional association |
Scarola is mentioned as being a member of the Florida bar.
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Timeline (2 events)
2020
A meeting where Scarola told the Government he had shown Carolyn a picture of an Epstein associate named Jane, but Carolyn could not identify the person.
Meetings between Carolyn and the Government.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the context of the Florida bar, of which Scarola is a member.
|
Relationships (4)
Scarola was present for Carolyn's meetings with the Government. The defendant wants Scarola to testify about Carolyn.
Carolyn is testifying against Ms. Maxwell.
Carolyn received money from her claims against Sarah Kellen.
Key Quotes (1)
"establish the timeline of Carolyn’s cooperation with the government and her motive and bias in testifying against Ms. Maxwell, in particular the fact that Carolyn was unresponsive and uncooperative until there was the prospect"Source
— The defendant
(The defendant's argument for why Scarola's testimony is relevant.)
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Quote #1
Full Extracted Text
Complete text extracted from the document (2,039 characters)
Case 1:20-cr-00330-PAE Document 545 Filed 12/15/21 Page 4 of 9
1681-83).
* Scarola was present for Carolyn’s the meetings the Government listed by the defense. (Tr. 1684; Def. Letter at 3-4).
* Carolyn received $2,804,000 from the Epstein Victims Compensation Program, not counting the $446,000 she had previously received from her claims against Epstein and Sarah Kellen (Tr. 1688-89).
Accordingly, the defendant has already obtained through Carolyn much of the testimony it anticipates from Scarola. There is no need for Scarola to testify to information already obtained from Carolyn, and it obviously does not impeach Carolyn for Scarola to confirm her answers.
Nearly all of additional testimony the defendant proposes to elicit from Scarola is irrelevant and non-impeaching. It does not matter that Scarola is a member of the Florida bar (Def. Letter at 2), nor are the additional specifics of the Government’s unsuccessful efforts to contact Carolyn probative (id. at 3).¹ It says nothing about Carolyn that Scarola copied counsel for other victims on an email. (id. at 2). None of that information impeaches Carolyn’s testimony in any way— rather, it is entirely consistent with her testimony.²
The defendant argues this testimony is relevant to “establish the timeline of Carolyn’s cooperation with the government and her motive and bias in testifying against Ms. Maxwell, in particular the fact that Carolyn was unresponsive and uncooperative until there was the prospect
¹ The Government would stipulate to the specific dates of meetings between Scarola, Carolyn, and the Government. (See Def. Letter at 3-4).
² The defendant would also elicit from Scarola that, during a 2020 meeting, Scarola told the Government that he had shown Carolyn a picture of the Epstein associate with the same name as Jane, but Carolyn could not identify the person at the time. But the defendant did not ask Carolyn about that person, so this testimony would not impeach Carolyn—to the extent it is not privileged.
² The defendant would also elicit from Scarola that, during a 2020 meeting, Scarola told the Government that he had shown Carolyn a picture of the Epstein associate with the same name as Jane, but Carolyn could not identify the person at the time. But the defendant did not ask Carolyn about that person, so this testimony would not impeach Carolyn—to the extent it is not privileged.
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