DOJ-OGR-00004712.jpg
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Extraction Summary
2
People
3
Organizations
2
Locations
4
Events
2
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
609 KB
Summary
This document is a preliminary statement from a legal memorandum filed by the U.S. Government on May 25, 2021, in the case against Ghislaine Maxwell. The Government argues that Maxwell's supplemental pre-trial motions should be denied, presenting five key reasons. These include the assertion that a non-prosecution agreement with Jeffrey Epstein is irrelevant to this case, the Double Jeopardy Clause does not apply, the charges are timely under the statute of limitations, and claims of prosecutorial delay are unfounded.
People (2)
| Name | Role | Context |
|---|---|---|
| GHISLAINE MAXWELL | Defendant |
Named as the defendant in the case UNITED STATES OF AMERICA -v.- GHISLAINE MAXWELL.
|
| Jeffrey Epstein |
Mentioned in relation to a non-prosecution agreement with the U.S. Attorney’s Office for the Southern District of Flo...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK | government agency |
The court where the case is being heard.
|
| UNITED STATES OF AMERICA | government agency |
The plaintiff in the case, referred to as "The Government".
|
| U.S. Attorney’s Office for the Southern District of Florida | government agency |
Party to a non-prosecution agreement with Jeffrey Epstein.
|
Timeline (4 events)
2021-02-26
Defendant’s twelve pre-trial motions were dated.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
2021-04-16
The Court’s Opinion and Order (the “April Opinion” or “Apr. Op.”) was dated.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
2021-05-07
Defendant's supplemental pre-trial motions (the “Defense Motions”) were dated.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
2021-05-25
The Government filed a memorandum in opposition to the defendant's supplemental pre-trial motions.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
Locations (2)
| Location | Context |
|---|---|
|
The location of the United States District Court hearing the case.
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|
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The location of the U.S. Attorney's Office that had a non-prosecution agreement with Jeffrey Epstein.
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Relationships (2)
Ghislaine Maxwell is the Defendant in a criminal case brought by the United States of America (the plaintiff/government).
The document mentions a non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney’s Office for the Southern District of Florida.
Full Extracted Text
Complete text extracted from the document (1,843 characters)
Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 5 of 26
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
----------------------------------------------------------x
SOUTHERN DISTRICT OF NEW YORK
----------------------------------------------------------x
UNITED STATES OF AMERICA
-v.- : S2 20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
:
Defendant. :
----------------------------------------------------------x
----------------------------------------------------------x
PRELIMINARY STATEMENT
The Government respectfully submits this memorandum in opposition to the defendant’s
supplemental pre-trial motions, dated May 7, 2021 (the “Defense Motions”). For the reasons that
follow, and for the reasons set forth in the Government’s memorandum in opposition to the
defendant’s twelve pre-trial motions, dated February 26, 2021, and the Court’s Opinion and Order,
dated April 16, 2021 (Dkt. No. 207, the “April Opinion” or “Apr. Op.”), the Defense Motions
should be denied in their entirety.
supplemental pre-trial motions, dated May 7, 2021 (the “Defense Motions”). For the reasons that
follow, and for the reasons set forth in the Government’s memorandum in opposition to the
defendant’s twelve pre-trial motions, dated February 26, 2021, and the Court’s Opinion and Order,
dated April 16, 2021 (Dkt. No. 207, the “April Opinion” or “Apr. Op.”), the Defense Motions
should be denied in their entirety.
First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney’s
Office for the Southern District of Florida does not apply to this District and does not bar the
prosecution of the defendant. Second, the Double Jeopardy Clause does not prohibit the
prosecution of the defendant, who has never previously risked conviction for the sex trafficking
offenses contained in Counts Five and Six of Indictment S2 20 Cr. 330 (the “S2 Indictment”).
Third, Counts Five and Six of the S2 Indictment, which plainly involve the sexual abuse of minors,
are timely under 18 U.S.C. § 3283, which provides an extended statute of limitations for such
crimes. Fourth, the defendant’s claim that the Government delayed in bringing the S2 Indictment
fails as a matter of law and fact. Fifth, the defendant’s motion to dismiss certain conspiracy counts
Office for the Southern District of Florida does not apply to this District and does not bar the
prosecution of the defendant. Second, the Double Jeopardy Clause does not prohibit the
prosecution of the defendant, who has never previously risked conviction for the sex trafficking
offenses contained in Counts Five and Six of Indictment S2 20 Cr. 330 (the “S2 Indictment”).
Third, Counts Five and Six of the S2 Indictment, which plainly involve the sexual abuse of minors,
are timely under 18 U.S.C. § 3283, which provides an extended statute of limitations for such
crimes. Fourth, the defendant’s claim that the Government delayed in bringing the S2 Indictment
fails as a matter of law and fact. Fifth, the defendant’s motion to dismiss certain conspiracy counts
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DOJ-OGR-00004712
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