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Extraction Summary
2
People
2
Organizations
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Locations
2
Events
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Relationships
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Quotes
Document Information
Type:
Legal document
File Size:
729 KB
Summary
This legal document is a filing on behalf of Ms. Maxwell, arguing against the government's request to preclude evidence of her 'good acts.' The defense asserts that evidence of Ms. Maxwell's absence during Mr. Epstein's alleged abuse of certain victims is admissible and crucial for demonstrating her lack of intent or knowledge, and that the government's motion to block this evidence is premature and legally flawed.
People (2)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
The subject of the legal filing, whose defense strategy and right to present evidence are being argued.
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| Mr. Epstein |
Mentioned in the context of his alleged abuse of victims, and Ms. Maxwell's presence or absence during these acts.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| The government | Government agency |
The prosecuting party in the case, whose requests and arguments are being countered by this document.
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| Court | Judicial body |
The legal entity being addressed in the filing, which the government has asked to make a ruling.
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Timeline (2 events)
Pre-trial motion regarding the admissibility of evidence for Ms. Maxwell's defense.
Court
Mr. Epstein allegedly abused victims and certain individuals.
Mr. Epstein
victims
Relationships (1)
The document discusses Ms. Maxwell's defense in the context of a conspiracy involving Mr. Epstein's alleged abuse of victims, focusing on her knowledge and presence during his acts.
Key Quotes (1)
"absence when Epstein abused victims who are not part of the government’s case-in-chief, . . . [she] explain the evidence she plans to offer and why such evidence would be admissible."Source
— The government
(A quote from a government motion (Mot. at 44) requesting the Court to require Ms. Maxwell to pre-approve evidence she intends to offer.)
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Quote #1
Full Extracted Text
Complete text extracted from the document (2,109 characters)
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 57 of 69
admissible to demonstrate the lack of any intent or knowledge on the part of Ms. Maxwell. As with the other in limine requests, this evidence will need to be evaluated on a question by question basis and it is premature to issue blanket rulings as requested by the government.
This case poses multi-jurisdictional issues that invite various defenses. The government has elected to prosecute, federally, conduct that is quintessentially state-based, and it is bound by its choice. It has charged offenses associated with coercion, force and violence, when such conduct did not occur in this case. It has alleged violation of a statute enacted to combat human trafficking, conduct that does not exist in this case. The government has manipulated federal statutes to fit alleged conduct that is not normally prosecuted federally and seeks to preclude defenses responsive to the allegations in the Indictment. It is premature to constrain Ms. Maxwell’s defense before trial. Ms. Maxwell reserves the right to present evidence and make argument on the issue of consent when and where appropriate.
VII. UNFOUNDED REQUEST TO PRECLUDE EVIDENCE OF MS. MAXWELL’S GOOD ACTS SHOULD BE SUMMARILY DENIED
The government asks this Court to require that, before Ms. Maxwell refers to or offers evidence of her “absence when Epstein abused victims who are not part of the government’s case-in-chief, . . . [she] explain the evidence she plans to offer and why such evidence would be admissible.” Mot. at 44. According to the government, evidence that Ms. Maxwell was “absent” when Mr. Epstein allegedly abused certain individuals is actually inadmissible “good acts” evidence because the jury could use it only to conclude that Ms. Maxwell acted in conformity with the prior good acts. Id. The government’s argument imagines a duty to provide notice where none exists, and it misunderstands what constitutes prior-act evidence and basic concepts of relevance in the context of a conspiracy where one actor denies knowledge of an illegal
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