This document is page 38 of a legal filing (Document 97) in the case against Ghislaine Maxwell, filed on December 14, 2020. The defense argues that the discovery provided by the government lacks contemporaneous evidence (emails, texts, diaries, police reports) implicating Maxwell in the alleged 1994-1997 conspiracy and claims that existing police reports are exculpatory rather than incriminating. Large portions of the text, specifically appearing to detail specific evidence or lack thereof, are redacted.
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Subject of the indictment; defense argues discovery materials do not implicate her.
|
| Complainants | Alleged Victims |
Referenced as 'the people we believe to be the complainants' and 'three complainants referenced in the indictment'.
|
| Government | Prosecution |
Referenced as 'the government's case against Ms. Maxwell'.
|
| Name | Type | Context |
|---|---|---|
| Law Enforcement |
Mentioned regarding police reports and reporting of alleged crimes.
|
|
| DOJ |
Department of Justice (implied by Bates stamp DOJ-OGR-00002010).
|
"The discovery also does not contain any police reports in which the people we believe to be the complainants reported the alleged crimes to law enforcement."Source
"To the contrary, the only police reports provided are exculpatory."Source
"In sum, the discovery contains not a single contemporaneous email, text message, phone record, diary entry, police report, or recording that implicates Ms. Maxwell in the 1994-1997 conduct underlying the conspiracy charged in the indictment."Source
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