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518 KB

Extraction Summary

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

Document Information

Type: Legal filing / court document (motion/memorandum)
File Size: 518 KB
Summary

This document is page 14 of a defense filing (Document 148) in United States v. Ghislaine Maxwell, dated February 4, 2021. The defense argues that the government is using a specific diary as 'contemporaneous documentary corroboration' against Maxwell to oppose bail, yet refuses to provide the full diary or the author's name to the defense. The filing requests the Court order the government to either produce the complete diary or identify the author so the defense can issue a subpoena before trial.

People (3)

Name Role Context
Ms. Maxwell Defendant
Subject of the criminal case; defense team is requesting documents on her behalf.
Diary's Author Witness/Source
Unnamed individual whose diary is being used as evidence by the government; identity is being withheld from the defense.
AJN Judge
Initials in the case number (Alison J. Nathan).

Organizations (3)

Name Type Context
The Government
Prosecution/Department of Justice.
The Court
Judicial body overseeing the case (SDNY).
DOJ-OGR
Department of Justice - Office of Government Relations (implied by Bates stamp prefix).

Timeline (3 events)

2021-02-04
Filing of Document 148
Court
Defense Counsel The Court
Prior to 2021-02-04
Ms. Maxwell's applications for bail
Court
Prior to 2021-02-04
Ms. Maxwell's second bail application
Court

Relationships (2)

The Government Adversarial (Prosecution vs. Defense) Ms. Maxwell
Government opposing bail applications; prosecuting case.
Diary's Author Witness/Evidence Source The Government
Government using author's diary as corroboration; protecting author's identity.

Key Quotes (3)

"the government relied heavily on the diary entries as contemporaneous documentary corroboration of their case against Ms. Maxwell."
Source
DOJ-OGR-00002707.jpg
Quote #1
"But because the government refuses to disclose her name to the defense, we don’t know who to subpoena and will not know until it is too late to obtain the diary in time for trial."
Source
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Quote #2
"Accordingly, we request the Court to order the government to produce a complete copy of the diary or, in the alternative, to identify the name of the diary’s author."
Source
DOJ-OGR-00002707.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,279 characters)

Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 14 of 23
(Dkt. 68) (emphasis added). Accordingly, the Court should order the government to produce
unredacted copies of these reports.
B. The Diary Pages
The government also produced in discovery [REDACTED]
[REDACTED] In opposing Ms. Maxwell’s
applications for bail, the government relied heavily on the diary entries as contemporaneous
documentary corroboration of their case against Ms. Maxwell. Yet [REDACTED]
[REDACTED]
[REDACTED]
[REDACTED] We
asked the government to produce a complete copy of the diary. The government responded that
[REDACTED]
[REDACTED]. In its opposition to Ms. Maxwell’s second bail application, the government further
represented that [REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED] If the government will not
obtain and produce the rest of the diary, Ms. Maxwell will have to issue a subpoena to the diary’s
author. But because the government refuses to disclose her name to the defense, we don’t know
who to subpoena and will not know until it is too late to obtain the diary in time for trial.
Accordingly, we request the Court to order the government to produce a complete copy of the
diary or, in the alternative, to identify the name of the diary’s author.
10
DOJ-OGR-00002707

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