DOJ-OGR-00008957.jpg
666 KB
Extraction Summary
6
People
1
Organizations
4
Locations
2
Events
3
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
666 KB
Summary
This legal document argues that the defense was hindered by the unavailability of contemporaneous phone and property records for Epstein, Ms. Maxwell, and accusers. It cites two examples: the inability to challenge Carolyn's testimony that Maxwell called her to set up appointments, and the inability to rebut accuser Jane's testimony about the timing of her sexual abuse at Epstein's New York townhouse, which she described in detail.
People (6)
| Name | Role | Context |
|---|---|---|
| Epstein |
Mentioned as having bought tickets for Jane, subject of phone and property records, and accused of sexually molesting...
|
|
| Jane | Accuser |
An accuser who took a trip to New York, saw The Lion King, and testified to being sexually molested by Epstein at his...
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| Ms. Maxwell |
Mentioned in relation to unavailable phone records and accused by Carolyn of calling to set up massage appointments, ...
|
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| Carolyn | Accuser |
Testified that Ms. Maxwell would call her to set up massage appointments. Her phone records, along with her mother's ...
|
| Carolyn's mother | Family member of accuser |
Her phone records were not available to the defense.
|
| Carolyn's boyfriend | Boyfriend of accuser |
His phone records were not available to the defense.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| FBI | government agency |
Jane had originally told the FBI she saw The Lion King on her first trip to New York.
|
Locations (4)
| Location | Context |
|---|---|
|
Mentioned as a possible destination for a trip by Jane.
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|
|
Location of Jane's first trip and the location of Epstein's home where alleged abuse occurred.
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Location of Epstein's townhouse in New York.
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Reference to Epstein's townhouse where a massage room was located.
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Relationships (3)
Jane testified that Epstein began sexually molesting her when she was 14. Epstein also bought her tickets to a Broadway show.
Carolyn testified that Ms. Maxwell would call her to set up massage appointments.
Their phone records are discussed together in the context of evidence for the defense.
Key Quotes (1)
"[I]t looked more like a building than a house. It was eight stories, his massive eight-story house building where you walk through these giant doors and then there was, like, another security door to go in. And it had an elevator and it was eight stories."Source
— Jane
(Jane's testimony describing Epstein's house in New York where she was allegedly molested.)
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Quote #1
Full Extracted Text
Complete text extracted from the document (1,914 characters)
Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 33 of 37
which would have dated her trip to New Mexico, or when Epstein bought tickets to the
Broadway production of The Lion King for Jane, which she had originally told the FBI she saw
on her first trip to New York. Tr. 503-11.
Broadway production of The Lion King for Jane, which she had originally told the FBI she saw
on her first trip to New York. Tr. 503-11.
C. Phone Records
Contemporaneous phone records for Epstein, Ms. Maxwell, the accusers, and others that
could have been used to rebut the government’s proof were also not available to the defense. For
example, Carolyn testified that Ms. Maxwell would call her to set up massage appointments. Tr.
1527. This was important evidence linking Ms. Maxwell to the sex trafficking charges in Counts
Five and Six. Carolyn’s claim could have been disproven with contemporaneous phone records.
However, because a complete set of Ms. Maxwell’s phone records—as well as phone records for
Carolyn, her mother, and her boyfriend—were not available, the defense could not challenge this
claim.
could have been used to rebut the government’s proof were also not available to the defense. For
example, Carolyn testified that Ms. Maxwell would call her to set up massage appointments. Tr.
1527. This was important evidence linking Ms. Maxwell to the sex trafficking charges in Counts
Five and Six. Carolyn’s claim could have been disproven with contemporaneous phone records.
However, because a complete set of Ms. Maxwell’s phone records—as well as phone records for
Carolyn, her mother, and her boyfriend—were not available, the defense could not challenge this
claim.
D. Property Records
The defense also did not have access to property records for Epstein’s various residences,
which would have rebutted the accusers’ testimony concerning the timing of the alleged sexual
abuse. For example, Jane testified that she began being sexually molested by Epstein in his
home in New York when she was 14 years old. Tr. 316-320. Jane described the house as
follows:
which would have rebutted the accusers’ testimony concerning the timing of the alleged sexual
abuse. For example, Jane testified that she began being sexually molested by Epstein in his
home in New York when she was 14 years old. Tr. 316-320. Jane described the house as
follows:
[I]t looked more like a building than a house. It was eight stories, his massive
eight-story house building where you walk through these giant doors and then
there was, like, another security door to go in. And it had an elevator and it was
eight stories.
eight-story house building where you walk through these giant doors and then
there was, like, another security door to go in. And it had an elevator and it was
eight stories.
Tr. 317. It is clear that Jane was describing Epstein’s townhouse on East 71st Street. Moreover,
her description of the massage room where she was molested matched photographs of the
massage room at the 71st Street house. Tr. 320. Jane turned 14 years old in August 1994. But
her description of the massage room where she was molested matched photographs of the
massage room at the 71st Street house. Tr. 320. Jane turned 14 years old in August 1994. But
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DOJ-OGR-00008957
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