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639 KB
Extraction Summary
4
People
2
Organizations
1
Locations
2
Events
2
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
639 KB
Summary
This legal document is a court's analysis of a defendant's claim that missing evidence—such as financial records, phone records, and flight manifests—was prejudicial to her case. The court rejects this argument, stating the defendant failed to demonstrate what the absent documents would have shown or how they would have been beneficial, concluding the claims are purely speculative. The court notes that the missing evidence could just as easily have further substantiated the government's case.
People (4)
| Name | Role | Context |
|---|---|---|
| the Countess |
Mentioned as the person who allegedly created a household manual, not the Defendant.
|
|
| Lynn Fontanilla | live-in housekeeper for Epstein |
Identified as a potential witness who could have testified about the Defendant's and Epstein's habits.
|
| Epstein |
Mentioned in relation to his housekeeper (Lynn Fontanilla), his habits, his residences, and potential payments to the...
|
|
| Defendant | Defendant |
The subject of the legal filing, arguing that missing evidence caused prejudice to her case. Mentioned throughout the...
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Court | Judicial body |
Mentioned as addressing the Defendant's arguments about documentary evidence.
|
| Government | Government agency |
Mentioned as having elicited testimony at trial and whose case may have been substantiated by the missing evidence.
|
Timeline (2 events)
2001-09-11
The date is used as a reference point for the level of detail in flight manifests, with those from before this date being 'far less detailed'.
The Government elicited testimony during a trial regarding the level of detail in flight manifests from before September 11, 2001.
Locations (1)
| Location | Context |
|---|---|
|
The location where Lynn Fontanilla was a live-in housekeeper for Epstein.
|
Relationships (2)
Lynn Fontanilla is described as a 'live-in housekeeper for Epstein in New York'.
Key Quotes (1)
"the Countess"Source
— Unknown (attributed)
(The document states that a witness could have testified that the household manual was created by 'the Countess,' not the Defendant.)
DOJ-OGR-00021023.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (2,161 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page197 of 221
A-397
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 40 of 45
A-397
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 40 of 45
2000s that could have testified the household manual was created by “the Countess,” not the
Defendant; and Lynn Fontanilla, a live-in housekeeper for Epstein in New York that could have
testified about the Defendant’s and Epstein’s habits.
Defendant; and Lynn Fontanilla, a live-in housekeeper for Epstein in New York that could have
testified about the Defendant’s and Epstein’s habits.
None of these identified pieces of alleged evidence satisfies the Defendant’s burden of
proving actual and substantial prejudice. The Court addresses first the documentary evidence.
First, the Defendant does not attest, or even suggest, what the absent documents are likely to
show. Though the Defendant would herself be best positioned to explain her own financial
transactions (or the lack thereof), her brief does not suggest what the absent financial records
would have shown. Similarly, the Defendant does not identify what would have been shown in
the absent phone records. The same is true of the flight records that the Defendant argues were
missing. At trial, the Government elicited testimony that flight manifests from before September
11, 2001, were far less detailed than modern manifests. E.g., Trial Tr. at 2518–22. The
Defendant can therefore only speculate that more accurate records ever existed. The location
and appearance of Epstein’s residences were also the source of significant testimony at trial. The
Defendant does not explain what additional information would have been contained in official
property records.
proving actual and substantial prejudice. The Court addresses first the documentary evidence.
First, the Defendant does not attest, or even suggest, what the absent documents are likely to
show. Though the Defendant would herself be best positioned to explain her own financial
transactions (or the lack thereof), her brief does not suggest what the absent financial records
would have shown. Similarly, the Defendant does not identify what would have been shown in
the absent phone records. The same is true of the flight records that the Defendant argues were
missing. At trial, the Government elicited testimony that flight manifests from before September
11, 2001, were far less detailed than modern manifests. E.g., Trial Tr. at 2518–22. The
Defendant can therefore only speculate that more accurate records ever existed. The location
and appearance of Epstein’s residences were also the source of significant testimony at trial. The
Defendant does not explain what additional information would have been contained in official
property records.
Second, even if more detail of the contents of these documents were presented, the
Defendant fails to show why the evidence, if admitted at trial, would have benefitted her case.
The Defendant’s motion presumes that each piece of missing evidence would have favored her:
an absence of payments by Epstein to the Defendant, an absence of phone calls from the
Defendant to victims, an absence of the victims on detailed flight manifests. But this
presumption is purely speculative. Each piece of evidence may very well have further
substantiated the Government’s case. Because the Defendant carries the burden of proof, she is
Defendant fails to show why the evidence, if admitted at trial, would have benefitted her case.
The Defendant’s motion presumes that each piece of missing evidence would have favored her:
an absence of payments by Epstein to the Defendant, an absence of phone calls from the
Defendant to victims, an absence of the victims on detailed flight manifests. But this
presumption is purely speculative. Each piece of evidence may very well have further
substantiated the Government’s case. Because the Defendant carries the burden of proof, she is
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DOJ-OGR-00021023
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