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697 KB
Extraction Summary
5
People
3
Organizations
0
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Court filing / legal memorandum (case 1:20-cr-00330-pae)
File Size:
697 KB
Summary
This document is a page from a defense filing in the Ghislaine Maxwell case, dated October 29, 2021. It argues that the Government's disclosure of Rule 404(b) evidence was insufficient and late, citing a letter served on October 11, 2021. The filing highlights discrepancies between the 404(b) letter and the trial exhibits provided the same day, specifically noting post-conspiracy evidence such as flight logs (2005-13), Amazon shipments (2013), and financial statements (2007) that were not justified in the letter.
People (5)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Associate of Defendant |
Mentioned as employer of a witness; recipient of Amazon shipment in 2013.
|
| Ghislaine Maxwell | Defendant |
Implied as 'the defendant'; document discusses the 'Maxwell Rule 404(b) letter'.
|
| [REDACTED] | Witness |
A witness who worked for Epstein after the charged conspiracy whom the Government 'may call' at trial.
|
| The Government | Prosecution |
Provided disclosure letters and exhibits; asserting admissibility of evidence.
|
| Defense Counsel | Defense |
Recipients of the Rule 404(b) letter.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| US District Court (SDNY) |
Case 1:20-cr-00330-PAE
|
|
| Amazon |
Source of a shipment to Jeffrey Epstein (Exhibit GX-423).
|
|
| Department of Justice (DOJ) |
Indicated by Bates stamp 'DOJ-OGR'.
|
Timeline (2 events)
October 11, 2021
Government served defense counsel the 'Maxwell Rule 404(b) letter'.
Court Proceedings
Government
Defense Counsel
Relationships (1)
witness... who worked for Epstein between [REDACTED]
Key Quotes (3)
"The Government asserted in the Letter that the evidence collectively was, in its opinion, 'direct evidence of the crimes charged and, in the alternative, pursuant to Rule 404(b) as proof of the defendant's intent, preparation, plan, knowledge, identity, and/or absence of mistake of (sic) accident.'"Source
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Quote #1
"[b]ecause this evidence is admissible as direct evidence."Source
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Quote #2
"None of these items of evidence were mentioned in the Maxwell Rule 404(b) Letter."Source
DOJ-OGR-00005615.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,021 characters)
Case 1:20-cr-00330-PAE Document 385 Filed 10/29/21 Page 6 of 12
229 at 3. This Court then ordered the Government to provide disclosure of any “Rule 404(b)
evidence and notice” by October 11. Dkt. 297.
evidence and notice” by October 11. Dkt. 297.
On October 11, 2021, the Government served on defense counsel a short letter entitled
the “Maxwell Rule 404(b) letter” (the “Rule 404(b) Letter” or the “Letter”), attached as Exhibit
A. In it, the Government referenced two sets of evidence: (a) [REDACTED]
[REDACTED], and
(b) a witness, [REDACTED] who worked for Epstein between [REDACTED] (after the
conclusion of the charged conspiracy) whom the Government said it “may call” at trial. The
Government asserted in the Letter that the evidence collectively was, in its opinion, “direct
evidence of the crimes charged and, in the alternative, pursuant to Rule 404(b) as proof of the
defendant's intent, preparation, plan, knowledge, identity, and/or absence of mistake of (sic)
accident.” Id. at 2. The Government stated it would not be moving in limine to seek the
evidence's admission "[b]ecause this evidence is admissible as direct evidence." Id. The Letter
lacked identification of any particular purpose for these two categories of evidence and lacked
any "basis for concluding that the evidence is relevant in light of this purpose."
the “Maxwell Rule 404(b) letter” (the “Rule 404(b) Letter” or the “Letter”), attached as Exhibit
A. In it, the Government referenced two sets of evidence: (a) [REDACTED]
[REDACTED], and
(b) a witness, [REDACTED] who worked for Epstein between [REDACTED] (after the
conclusion of the charged conspiracy) whom the Government said it “may call” at trial. The
Government asserted in the Letter that the evidence collectively was, in its opinion, “direct
evidence of the crimes charged and, in the alternative, pursuant to Rule 404(b) as proof of the
defendant's intent, preparation, plan, knowledge, identity, and/or absence of mistake of (sic)
accident.” Id. at 2. The Government stated it would not be moving in limine to seek the
evidence's admission "[b]ecause this evidence is admissible as direct evidence." Id. The Letter
lacked identification of any particular purpose for these two categories of evidence and lacked
any "basis for concluding that the evidence is relevant in light of this purpose."
Also on October 11, the Government provided its anticipated trial exhibits. Even a quick
review of those exhibits reflects the Government's apparent intent to offer numerous documents
and other evidence that purportedly occurred after the conclusion of the charged conspiracy.
See, e.g., GX-4-D through GX-4-K (message pads dated beginning in 2005); GX-423 (an
Amazon shipment to Jeffrey Epstein of an iPhone USB lightning cable in 2013); GX-501 & 502
(financial statements from June 2007); GX-661 & 662 (flight logs from 2005-13). None of these
items of evidence were mentioned in the Maxwell Rule 404(b) Letter. The Government's theory
of admissibility concerning this post-2004 evidence remains unclear.
review of those exhibits reflects the Government's apparent intent to offer numerous documents
and other evidence that purportedly occurred after the conclusion of the charged conspiracy.
See, e.g., GX-4-D through GX-4-K (message pads dated beginning in 2005); GX-423 (an
Amazon shipment to Jeffrey Epstein of an iPhone USB lightning cable in 2013); GX-501 & 502
(financial statements from June 2007); GX-661 & 662 (flight logs from 2005-13). None of these
items of evidence were mentioned in the Maxwell Rule 404(b) Letter. The Government's theory
of admissibility concerning this post-2004 evidence remains unclear.
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DOJ-OGR-00005615
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