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715 KB
Extraction Summary
5
People
2
Organizations
2
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing / court motion (government motion in limine or similar evidentiary filing)
File Size:
715 KB
Summary
This document is page 40 of a legal filing (Case 1:20-cr-00330-PAE) from October 29, 2021, arguing for the admissibility of testimony from 'Employee-1'. The text details that Employee-1 will testify that in October 2005, Epstein and a supervisor ordered the removal of computers and contact books from the house. The government argues this testimony proves the defendant's role in the conspiracy, knowledge of the abuse of underage girls, and authenticates exhibits.
People (5)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Deceased / Co-conspirator |
Directed removal of evidence; engaged in sexual abuse of underage girls.
|
| The Defendant | Defendant |
Ghislaine Maxwell (implied by case number 1:20-cr-00330); Name redacted in text. Accused of conspiracy and preparatio...
|
| Employee-1 | Witness / Former Employee |
Will testify about removing computers/books and the operation of Epstein's homes.
|
| Supervisor | Staff |
Supervisor of Employee-1 who helped direct the removal of items.
|
| Specified individual | Unknown recipient |
Person who received the computers and contact books removed from the house.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
Arguing for admissibility of evidence and compliance with notice obligations.
|
|
| DOJ |
Department of Justice (indicated in footer stamp).
|
Timeline (2 events)
Locations (2)
| Location | Context |
|---|---|
|
Epstein's residence where computers and contact books were gathered.
|
|
|
General reference to properties where lifestyle and operations occurred.
|
Relationships (2)
Testimony shows relationship shortly after end of conspiracy period, including defendant's role in Epstein's affairs.
Epstein directed her to gather computers.
Key Quotes (3)
"Employee-1 to testify that in or about October 2005, Epstein and her supervisor directed her to gather the computers and contact books in the house and hand them over to a specified individual."Source
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Quote #1
"Employee-1’s testimony will also show the defendant and Epstein’s plan and preparation, because it will describe the process and frequency of obtaining masseuses, including the fact that the masseuses were often underage girls"Source
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Quote #2
"some of the massages developed into sexual abuse"Source
DOJ-OGR-00005823.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,085 characters)
Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 40 of 84
Employee-1 to testify that in or about October 2005, Epstein and her supervisor directed her to
gather the computers and contact books in the house and hand them over to a specified individual.
gather the computers and contact books in the house and hand them over to a specified individual.
Employee-1’s testimony is admissible for multiple permissible purposes. Her testimony
shows the relationship between Epstein and the defendant [REDACTED], shortly after the end of the
conspiracy period, including the defendant’s role in Epstein’s affairs. Similarly, it provides
background information about the operation of Epstein’s homes and lifestyle. Employee-1’s
testimony will also show the defendant and Epstein’s plan and preparation, because it will describe
the process and frequency of obtaining masseuses, including the fact that the masseuses were often
underage girls, and that some of the massages developed into sexual abuse. And Employee-1’s
testimony tends to show the defendant’s knowledge, because it describes the visibility of Epstein’s
abuse to individuals at his properties. Finally, Employee-1’s testimony will authenticate exhibits
that are direct evidence of the charged crimes. Accordingly, Employee-1’s testimony is direct
evidence of the crimes charged. Moreover, this evidence is admissible in the alternative under
Rule 404(b), for substantially the same reasons.
shows the relationship between Epstein and the defendant [REDACTED], shortly after the end of the
conspiracy period, including the defendant’s role in Epstein’s affairs. Similarly, it provides
background information about the operation of Epstein’s homes and lifestyle. Employee-1’s
testimony will also show the defendant and Epstein’s plan and preparation, because it will describe
the process and frequency of obtaining masseuses, including the fact that the masseuses were often
underage girls, and that some of the massages developed into sexual abuse. And Employee-1’s
testimony tends to show the defendant’s knowledge, because it describes the visibility of Epstein’s
abuse to individuals at his properties. Finally, Employee-1’s testimony will authenticate exhibits
that are direct evidence of the charged crimes. Accordingly, Employee-1’s testimony is direct
evidence of the crimes charged. Moreover, this evidence is admissible in the alternative under
Rule 404(b), for substantially the same reasons.
2. The Government Has Met and Exceeded Its Notice Obligations
Even if Rule 404(b) applies here, the Government’s October 11, 2021 letter—and the
corresponding Jencks Act disclosures—have satisfied any notice obligations that apply here.
Even if Rule 404(b) applies here, the Government’s October 11, 2021 letter—and the
corresponding Jencks Act disclosures—have satisfied any notice obligations that apply here.
The defense claims that the Government’s October 11, 2021 notice was inadequate in light
of the 2020 amendments to Rule 404(b). The Government provided the defense with a letter, and
corresponding disclosures, seven weeks before trial. In fact, the defense has had the seven exhibits
for much longer, since they were part of the Government’s Rule 16 discovery productions. The
defense now also has this briefing, five weeks before trial. Thus, any alleged gap in the
of the 2020 amendments to Rule 404(b). The Government provided the defense with a letter, and
corresponding disclosures, seven weeks before trial. In fact, the defense has had the seven exhibits
for much longer, since they were part of the Government’s Rule 16 discovery productions. The
defense now also has this briefing, five weeks before trial. Thus, any alleged gap in the
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