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747 KB
Extraction Summary
4
People
4
Organizations
1
Locations
1
Events
2
Relationships
4
Quotes
Document Information
Type:
Court filing / legal motion (defense)
File Size:
747 KB
Summary
This document is page 59 of a court filing (Document 382) in the case against Ghislaine Maxwell, filed on October 29, 2021. The defense argues against the government's motion to exclude evidence, asserting that they have the right to reference evidence in opening statements if they have a good-faith belief it is admissible. Specifically, the defense intends to introduce evidence showing that Jeffrey Epstein abused many victims without Maxwell's knowledge or participation, arguing this is relevant to refuting the conspiracy charge, while the government attempts to characterize this as inadmissible 'good acts' or 'propensity' evidence.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the legal defense arguments regarding admissibility of evidence and opening statements.
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| Jeffrey Epstein | Alleged Co-conspirator |
Mentioned as having committed acts of abuse without Maxwell's knowledge or participation.
|
| Ms. Maxwell's attorneys | Defense Counsel |
Referenced regarding their good-faith belief in admissible evidence for opening statements.
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| Accusers | Victims/Witnesses |
Referenced in relation to specific specified accusers versus other minors abused by Epstein.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Government |
Prosecution team filing motions to exclude evidence.
|
|
| ABA (American Bar Association) |
Cited for Criminal Justice Standards regarding opening statements.
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| United States District Court |
Implicitly the court handling Case 1:20-cr-00330-PAE.
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| DOJ |
Department of Justice (referenced in footer stamp).
|
Timeline (1 events)
2021-10-29
Filing of Document 382 in Case 1:20-cr-00330-PAE
Court Record
Defense Counsel
The Court
Locations (1)
| Location | Context |
|---|---|
|
Western District of New York (cited in case law United States v. Rounds).
|
Relationships (2)
Defense argues Epstein committed abuse 'Without Ms. Maxwell's Knowledge or Participation' to disprove conspiracy elements.
Document discusses the government's motion to exclude evidence favorable to Maxwell.
Key Quotes (4)
"The Referenced Evidence Demonstrates that Jeffrey Epstein Committed Acts of Abuse -- Without Ms. Maxwell's Knowledge or Participation – May Be Relevant to Existence of Conspiracy or Knowledge of Its Illegal Objectives."Source
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Quote #1
"The government seeks to exclude evidence that 'many victims who were sexually abused by Epstein…did not have personal interactions or dealings with the defendant, including during the time period of the charged conspiracy.'"Source
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Quote #2
"The government characterizes this evidence as 'good acts' of Ms. Maxwell... they are neither 'good,' nor Ms. Maxwell's 'acts.'"Source
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Quote #3
"Defense counsel’s opening statement at trial should be confined to a fair statement of the case from defense counsel’s perspective"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,169 characters)
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 59 of 69
Because nothing requires Ms. Maxwell to advise the government in advance of the
evidence she intends to admit at trial or why that evidence is relevant, this Court should deny the
government’s motion. If Ms. Maxwell’s attorneys have a good-faith belief that evidence will be
admissible, they can refer to that evidence in opening statement. ABA Criminal Justice
Standards, Defense Function, Standard 4-7.5(b) Opening Statement at Trial (“Defense counsel’s
opening statement at trial should be confined to a fair statement of the case from defense
counsel’s perspective, and discussion of evidence that defense counsel reasonably believes in
good faith will be available, offered, and admitted.”). When the defense offers evidence, the
government can make any objections it thinks are appropriate, and this Court can rule on the
objections in context. See United States v. Rounds, No. 10-CR-239S (1)(2)(3), 2015 WL
5918372, at *1 (W.D.N.Y. Oct. 9, 2015) (“Without hearing the evidence in context, this Court
cannot enter a blanket pretrial ruling. The government’s motion in limine is therefore denied as
premature, without prejudice to the government raising this issue at an appropriate time during
trial.”).
evidence she intends to admit at trial or why that evidence is relevant, this Court should deny the
government’s motion. If Ms. Maxwell’s attorneys have a good-faith belief that evidence will be
admissible, they can refer to that evidence in opening statement. ABA Criminal Justice
Standards, Defense Function, Standard 4-7.5(b) Opening Statement at Trial (“Defense counsel’s
opening statement at trial should be confined to a fair statement of the case from defense
counsel’s perspective, and discussion of evidence that defense counsel reasonably believes in
good faith will be available, offered, and admitted.”). When the defense offers evidence, the
government can make any objections it thinks are appropriate, and this Court can rule on the
objections in context. See United States v. Rounds, No. 10-CR-239S (1)(2)(3), 2015 WL
5918372, at *1 (W.D.N.Y. Oct. 9, 2015) (“Without hearing the evidence in context, this Court
cannot enter a blanket pretrial ruling. The government’s motion in limine is therefore denied as
premature, without prejudice to the government raising this issue at an appropriate time during
trial.”).
B. The Referenced Evidence Demonstrates that Jeffrey Epstein Committed Acts of
Abuse -- Without Ms. Maxwell's Knowledge or Participation – May Be
Relevant to Existence of Conspiracy or Knowledge of Its Illegal Objectives.
Abuse -- Without Ms. Maxwell's Knowledge or Participation – May Be
Relevant to Existence of Conspiracy or Knowledge of Its Illegal Objectives.
The government seeks to exclude evidence that "many victims who were sexually abused
by Epstein…did not have personal interactions or dealings with the defendant, including during
the time period of the charged conspiracy." Mot. at 42. The government characterizes this
evidence as "good acts" of Ms. Maxwell (id. at 41-42); they are neither "good," nor Ms.
Maxwell's "acts." Rather, relying on inapposite cases, the government seeks to exclude as
"propensity" evidence the fact that Mr. Epstein sexually abused minors (other than the specified
Accusers) without Ms. Maxwell's knowledge and involvement. The government conveniently
overlooks that:
by Epstein…did not have personal interactions or dealings with the defendant, including during
the time period of the charged conspiracy." Mot. at 42. The government characterizes this
evidence as "good acts" of Ms. Maxwell (id. at 41-42); they are neither "good," nor Ms.
Maxwell's "acts." Rather, relying on inapposite cases, the government seeks to exclude as
"propensity" evidence the fact that Mr. Epstein sexually abused minors (other than the specified
Accusers) without Ms. Maxwell's knowledge and involvement. The government conveniently
overlooks that:
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