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Extraction Summary

6
People
3
Organizations
0
Locations
2
Events
2
Relationships
2
Quotes

Document Information

Type: Court filing / legal brief (government memorandum)
File Size: 536 KB
Summary

This document is page 15 of a Government filing dated October 29, 2021, in the case against Ghislaine Maxwell (Case 1:20-cr-00330). It discusses the Government's proposal to protect the identities of Minor Victims 1, 3, 4, and 6 through the use of pseudonyms or first names only during testimony. The text explicitly links the 'intimate details of childhood sexual abuse' to both the defendant and Jeffrey Epstein.

People (6)

Name Role Context
Jeffrey Epstein Co-conspirator / Abuser
Mentioned as having committed childhood sexual abuse alongside the defendant.
The Defendant Defendant (Ghislaine Maxwell)
Accused of committing childhood sexual abuse alongside Epstein.
Minor Victim-1 Victim / Witness
Proposed to testify under pseudonym.
Minor Victim-3 Victim / Witness
Proposed to testify under pseudonym.
Minor Victim-4 Victim / Witness
Proposed to testify under first name only.
Minor Victim-6 Victim / Potential Witness
Proposed to be referred to by first name; Government states she will not be a witness or hearsay declarant.

Organizations (3)

Name Type Context
The Government
Proposing privacy protections for victims.
Defense
Mentioned in footnote regarding their opposition brief (Def. Opp.).
DOJ-OGR
Source of the document (Bates stamp).

Timeline (2 events)

Historical
Childhood sexual abuse
Unspecified
Upcoming (relative to Oct 2021)
Trial (United States v. Ghislaine Maxwell)
Court
The Defendant Government Minor Victims

Relationships (2)

The Defendant Co-abusers Jeffrey Epstein
Text references abuse 'at the hands of the defendant and Jeffrey Epstein'.
Minor Victim-1 Witness for Prosecution The Government
Government proposes permitting them to testify.

Key Quotes (2)

"The question is not whether the victims’ testimony—that is, the intimate details of their childhood sexual abuse at the hands of the defendant and Jeffrey Epstein—will become public."
Source
DOJ-OGR-00005569.jpg
Quote #1
"Minor Victim-6 will not be a witness or hearsay declarant at this trial."
Source
DOJ-OGR-00005569.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (1,439 characters)

Case 1:20-cr-00330-PAE Document 383 Filed 10/29/21 Page 15 of 40
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C. The Government’s Proposal Would Protect Those Privacy Interests
The Government has proposed permitting Minor Victim-1, Minor Victim-3, and two
witnesses related to Minor Victim-1 to testify under pseudonyms, and limiting reference to them
at trial to those pseudonyms. The Government has also proposed permitting Minor Victim-4 and
certain witnesses related to her to testify under their first names, and limiting reference to those
witnesses and Minor Victim-6 to their first names.
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.
This proposal would successfully protect the victim privacy interests identified above. The
question is not whether the victims’ testimony—that is, the intimate details of their childhood
sexual abuse at the hands of the defendant and Jeffrey Epstein—will become public. They will,
and in light of the publicity surrounding this case, those details are likely to be highly publicized.
The question is whether those details will be linked to the names of the Minor Victims. Under the
________
8 Although the defense also says it needs to investigate Minor Victim-6 as a “potential witness”
(Def. Opp. at 20), as the Government has said before, Minor Victim-6 will not be a witness or
hearsay declarant at this trial.
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DOJ-OGR-00005569

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