DOJ-OGR-00005831.jpg
702 KB
Extraction Summary
7
People
2
Organizations
0
Locations
3
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
702 KB
Summary
This legal document, part of a court filing, argues against precluding the testimony of 'Minor Victim-3' in the trial of the defendant, Maxwell. The prosecution contends that even if the acts against this victim were uncharged, her testimony is crucial to establish a pattern of abuse, show the defendant's relationship with Epstein, and prove her knowing participation in a conspiracy. The document cites legal precedent to support delaying any decision to strike this evidence until after the government has presented its case at trial.
People (7)
| Name | Role | Context |
|---|---|---|
| Maxwell | Defendant |
Mentioned in relation to her 'state of mind' and her relationship with Epstein and Minor Victim-3. Referred to as 'th...
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| Epstein |
Mentioned in the context of the defendant's relationship with him, her willingness to procure teenagers for him, and ...
|
|
| Minor Victim-3 | Victim |
The relevance of her testimony is being discussed. The document details the defendant's acts toward her and the timel...
|
| Minor Victim-1 | Victim |
Mentioned as another victim who experienced abuse in close temporal proximity to Minor Victim-3. The conduct involvin...
|
| Minor Victim-2 | Victim |
Mentioned as another victim who experienced abuse in close temporal proximity to Minor Victim-3. The conduct involvin...
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| Carboni |
Mentioned in a legal citation: 'Carboni, 204 F.3d at 44'.
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|
| Romero-Padilla |
Mentioned in a legal citation: 'United States v. Romero-Padilla, 583 F.3d 126, 130 (2d Cir. 2009)'.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Referred to as 'the Government's evidence' and 'Government's proof at trial'.
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| Court | judicial body |
Mentioned as 'the Court' and 'Courts in this district', in the context of ruling on motions.
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Timeline (3 events)
Relationships (2)
The document states the defendant's acts show her 'relationship with Epstein' and her 'agreement to participate in a conspiracy with Epstein'.
The document describes the defendant's 'acts toward Minor Victim-3' and states her relationship with the victim was 'part of [her] continued effort' to commit offenses.
Key Quotes (3)
"Courts in this district generally delay ruling on any motion to strike until after the presentation of the Government’s evidence at trial, because that evidence may affect how specific allegations relate to the overall charges."Source
— Op. & Order at 26-27, Dkt. No. 207
(Quoted from a previous court order to support the argument that the court should delay striking evidence.)
DOJ-OGR-00005831.jpg
Quote #1
"part of [her] continued effort"Source
— Unknown
(Describing the defendant's relationship with Minor Victim-3 as part of her effort to commit offenses.)
DOJ-OGR-00005831.jpg
Quote #2
"We reject Romero-Padilla’s contention that evidence of his"Source
— 2d Cir. Court
(Quoted from the legal case United States v. Romero-Padilla.)
DOJ-OGR-00005831.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,048 characters)
Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 48 of 84
Maxwell’s state of mind.” (Op. & Order at 26-27, Dkt. No. 207 (“Courts in this district generally delay ruling on any motion to strike until after the presentation of the Government’s evidence at trial, because that evidence may affect how specific allegations relate to the overall charges.”)). Having concluded that it should delay striking these overt acts until after presentation of the Government’s evidence, the Court should not now effectively reverse its decision by precluding that very evidence. If the Government’s proof at trial does not establish the relevance of Minor Victim-3’s testimony, if anything, the proper course is for the defense to move to strike the relevant overt acts and Minor Victim-3’s testimony at that time.
Even if evidence of Minor Victim-3 were uncharged criminal activity, it would still be necessary to understand the other aspects of the charged conspiracies. Minor Victim-3 experienced the pattern of abuse in close temporal proximity to the other Minor Victims: the conduct involving Minor Victim-1 spans 1994 to 1997, the conduct involving Minor Victim-3 spans 1994 to 1995, and the conduct involving Minor Victim-2 occurred in 1996. The defendant’s acts toward Minor Victim-3 show (1) the defendant’s relationship with Epstein, including her willingness to procure teenagers to give Epstein massages, (2) the defendant’s knowledge of both the sexual nature of those massages and the need to procure additional victims, and (3) her willingness to transport minors to further their abuse. This evidence is therefore direct proof of the defendant’s state of mind and agreement to participate in a conspiracy with Epstein. Moreover, her relationship with Minor Victim-3 was “part of [her] continued effort” to commit the offenses charged in Counts One and Three. Carboni, 204 F.3d at 44; see United States v. Romero-Padilla, 583 F.3d 126, 130 (2d Cir. 2009) (“We reject Romero-Padilla’s contention that evidence of his
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DOJ-OGR-00005831
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