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630 KB
Extraction Summary
4
People
1
Organizations
0
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Court filing / legal brief (government response)
File Size:
630 KB
Summary
This page from a 2021 court filing (Case 1:20-cr-00330-PAE) presents arguments regarding the defendant's (Ghislaine Maxwell) perjury or false statements. It quotes a deposition where the defendant unequivocally denies ever giving anyone a massage, specifically denying giving massages to Mr. Epstein or '[Minor Victim-2].' The government argues that these answers were not ambiguous and that a jury could conclude the defendant lied.
People (4)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant / Deponent |
The person whose testimony is being analyzed (Ghislaine Maxwell, based on case number 1:20-cr-00330). She denies givi...
|
| Mr. Epstein | Associate of Defendant |
Subject of questioning; defendant denied giving him a massage.
|
| [Minor Victim-2] | Alleged Victim |
Subject of questioning; defendant denied giving this person a massage.
|
| Giuffre | Plaintiff (Civil Case) |
Mentioned as 'Giuffre's counsel,' indicating the deposition took place during the Giuffre civil litigation.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| DOJ |
Department of Justice (indicated by footer stamp DOJ-OGR)
|
Timeline (2 events)
2021-04-16
Filing of Document 204 in Case 1:20-cr-00330-PAE
Court Record
Defense Counsel
Prosecution
Unknown (Past)
Relationships (3)
Questioned about giving him a massage; denied.
Questioned about giving this person a massage; denied.
Reference to 'Giuffre's counsel' conducting the deposition.
Key Quotes (4)
"I have not given anyone a massage."Source
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Quote #1
"I never gave [Minor Victim-2] a massage."Source
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Quote #2
"The defendant’s argument is, yet again, misguided."Source
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Quote #3
"A properly instructed jury could conclude that the defendant meant what she said: she never gave anyone a massage, including Epstein and Minor Victim-2."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,763 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 161 of 239
Q. I will ask that question if you want, but I was focusing on people other than Mr. Epstein right now.
A. I don’t give massages.
Q. Let's just tie that down. It is your testimony that you’ve never given anybody a massage?
A. I have not given anyone a massage.
Q. You never gave Mr. Epstein a massage, is that your testimony?
A. That is my testimony.
Q. You never gave [Minor Victim-2] a massage is your testimony?
A. I never gave [Minor Victim-2] a massage.
(Ex. 11 at 112:17-113:12).
The defendant argues that these questions were fundamentally ambiguous because the deposition elsewhere discussed both sexual and professional massages. It was unclear, she explains, what kind of massage the questioner meant. (Def. Mot. 4 at 17.) The defendant’s argument is, yet again, misguided. This line of questioning used broad language, and at no point during this set of questions did Giuffre’s counsel suggest that the questions were limited to sexual or professional massages. Cf. Lighte, 782 F.2d at 376 (concluding that the word “you” was ambiguous when the prior two questions asked about the defendant “as an individual” and then switched “without indication” to the defendant “as trustee”). The defendant’s answers were unequivocal, with no expressions of confusion or internal contradictions. Cf. Markiewicz, 978 F.2d at 809 (explaining that a question was ambiguous as to whether it asked about the deponent’s personal or professional capacities, in light of the deponent’s confusion in the next questions). A properly instructed jury could conclude that the defendant meant what she said: she never gave anyone a massage, including Epstein and Minor Victim-2.
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