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724 KB
Extraction Summary
6
People
2
Organizations
0
Locations
4
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
724 KB
Summary
This legal document is a filing that argues against a defendant's motion. The defendant claims that testimony from Michael Casey (agent for Minor Victim-1) and Detective Recarey would have been exculpatory. The filing counters that this proposed testimony is speculative, unsubstantiated, likely inadmissible hearsay, and ultimately irrelevant to the charges that the defendant assisted Epstein in the grooming and abuse of other victims.
People (6)
| Name | Role | Context |
|---|---|---|
| Casey |
Mentioned as an individual whose testimony the defendant claims would have been exculpatory. Full name is later ident...
|
|
| Detective Recarey | Detective |
Mentioned as an individual whose testimony the defendant claims would have been exculpatory, specifically regarding a...
|
| Michael Casey | purported agent of Minor Victim-1 |
Identified as the person the defendant contends would testify about Minor Victim-1's behavior and lack of complaints.
|
| Minor Victim-1 | Victim |
An individual whose behavior and alleged lack of outcry Michael Casey would have testified about.
|
| Maxwell |
Mentioned as 'Ms. Maxwell', a person to whom complaints were allegedly not made.
|
|
| Epstein |
Mentioned in the context of having potentially abused victims without the defendant's participation.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Court | government agency |
Referenced as the body before which there is no evidence of what Casey would have testified.
|
| Government | government agency |
Mentioned in the context of rebutting the 'Government's evidence' with respect to the charged conduct.
|
Timeline (4 events)
Defendant's trial, where the admissibility of potential testimony from Casey and Detective Recarey is being discussed.
A prior investigation in which Detective Recarey spoke with witnesses.
Alleged sex trafficking activities that the defendant is accused of participating in.
defendant
Relationships (3)
Michael Casey is described as the 'purported agent of Minor Victim-1'.
The document states 'the fact that Epstein may have abused victims'.
defendant
→
accomplice-victim
→
other victims
The document mentions 'charges alleging the defendant assisted in the grooming and abuse of other victims'.
Key Quotes (3)
"would be able to testify” about Minor Victim-1’s behavior during the “relevant time period” and the “lack of any ‘outcry’ or ‘grooming.’"Source
— defendant (contention)
(Describing the defendant's claim about what Michael Casey's testimony would cover.)
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Quote #1
"any authority, Ms. Maxwell, or any other known witness"Source
— defendant (suggestion)
(Listing entities to whom Casey allegedly did not relate any complaints about Maxwell.)
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Quote #2
"there is no evidence before the Court as to what [Casey] would have testified."Source
— Scala, 388 F. Supp. 2d at 400
(A legal citation used to argue that the defendant's claims about Casey's potential testimony are unsubstantiated.)
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,131 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 74 of 239
2018 respectively, would have testified, and that such testimony would have been exculpatory and would have materially helped the defense. (Def. Mot. 7 at 9-11). The defendant cannot establish that Casey and Detective Recarey would have testified in a way that would help, rather than hurt, the defendant.
In particular, the defendant contends that Michael Casey, the purported agent of Minor Victim-1, “would be able to testify” about Minor Victim-1’s behavior during the “relevant time period” and the “lack of any ‘outcry’ or ‘grooming.’” (Id. at 10). The defense suggests that Casey not having related any complaints about Maxwell to “any authority, Ms. Maxwell, or any other known witness” means that he knew of no complaints. (Id. at 9-10). As an initial matter, “there is no evidence before the Court as to what [Casey] would have testified.” Scala, 388 F. Supp. 2d at 400. Even assuming that Casey would have testified as the defendant now contends, such testimony (which would be purely speculative and unsubstantiated) would also have no bearing on whether the abuse, in fact, occurred.
The defendant argues that Detective Recarey would have testified that none of the witnesses with whom he spoke in connection with a prior investigation told him about the defendant participating in sex trafficking activities. (Def. Mot. 7 at 10-11). As a threshold matter, the defendant has not established how such testimony, which would consist entirely of hearsay, could even be admissible at the defendant’s trial. Moreover, the fact that Epstein may have abused victims without the defendant’s participation is not exculpatory as to charges alleging the defendant assisted in the grooming and abuse of other victims. The well-established law of this Circuit generally precludes a defendant from offering evidence that a defendant did not participate in criminal conduct on a particular occasion—or of her law-abiding conduct during uncharged periods or uncharged events—to rebut the Government’s evidence with respect to the charged
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DOJ-OGR-00003008
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