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621 KB
Extraction Summary
6
People
4
Organizations
0
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal filing / court document (motion to suppress / memorandum of law)
File Size:
621 KB
Summary
This document is page 7 of a legal filing (Motion to Suppress) from February 4, 2021, in the criminal case against Ghislaine Maxwell. The defense argues that the government made untrue representations regarding a redacted source who was instrumental in the prosecution and provided information before the investigation began. The text asserts that Maxwell would not have agreed to civil depositions in the 'Giuffre v. Maxwell' case without the Protective Order, and argues the court should suppress the fruits of the government's misrepresentation, specifically the perjury counts arising from those depositions.
People (6)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the prosecution; alleged to have committed perjury during civil depositions.
|
| Virginia Giuffre | Plaintiff (Civil Case) |
Filed a defamation case against Maxwell in 2015; alleged victim of abuse/trafficking.
|
| Jeffrey Epstein | Alleged Perpetrator |
Accused of sexually abusing and trafficking Giuffre with Maxwell's participation.
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| Mary McCarthy | Historical Figure |
Referenced in a quote/metaphor about untruthfulness.
|
| Lillian Hellman | Historical Figure |
Referenced in a quote/metaphor about untruthfulness.
|
| Norman Mailer | Author |
Cited in Footnote 1.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Government |
Accused of making untrue representations and having previous contact with a redacted entity.
|
|
| The Court |
Asked to suppress evidence or grant a hearing.
|
|
| New York Times |
Source cited in footnote.
|
|
| DOJ |
Department of Justice, indicated in Bates stamp.
|
Timeline (2 events)
2015
Filing of civil defamation case Giuffre v. Maxwell
Civil Court (implied)
Relationships (3)
Document mentions scheme to cause Giuffre to be sexually abused and trafficked by Jeffrey Epstein.
Plaintiff and Defendant in Giuffre v. Maxwell defamation case.
Government had previous contact with [Redacted]; [Redacted] provided information well before investigation began.
Key Quotes (4)
"every word of the government’s representation was untrue, 'including ‘and’ and ‘the.’”"Source
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Quote #1
"[Redacted] was instrumental in fomenting the Maxwell prosecution."Source
DOJ-OGR-00002354(3).jpg
Quote #2
"Maxwell committed perjury during two civil depositions taken in Giuffre v. Maxwell"Source
DOJ-OGR-00002354(3).jpg
Quote #3
"Maxwell had participated in a scheme to cause Giuffre to be “sexually abused and trafficked” by Jeffrey Epstein."Source
DOJ-OGR-00002354(3).jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,746 characters)
Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 7 of 23
To paraphrase Mary McCarthy’s philippic about Lillian Hellman, every word of the government’s representation was untrue, “including ‘and’ and ‘the.’”1 The government knew what was in the [REDACTED] had provided that information well before the investigation began. The government did indeed have previous contact with [REDACTED]. And [REDACTED] was instrumental in fomenting the Maxwell prosecution.
The record is surpassingly clear: But for the [REDACTED] never would have permitted the circumvention of the civil Protective Order, on which Maxwell relied in agreeing to sit for her depositions. This Court therefore has both the authority and the duty to suppress the fruits of that misrepresentation, including the [REDACTED] and the two perjury counts based on those transcripts. If the Court is disinclined to exercise that inherent authority on the present record, Maxwell should be granted a hearing to examine the circumstances that resulted in the [REDACTED].
FACTUAL BACKGROUND
A. The Protective Order in Giuffre v. Maxwell
Counts Five and Six of the superseding indictment allege that Maxwell committed perjury during two civil depositions taken in Giuffre v. Maxwell, a civil defamation case Virginia Giuffre filed in 2015. Giuffre claimed that Maxwell defamed her when Maxwell’s attorney-hired press agent denied as “untrue” and “obvious lies” Giuffre’s numerous allegations, over the span of four years, that Maxwell had participated in a scheme to cause Giuffre to be “sexually abused and trafficked” by Jeffrey Epstein.
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1 See Norman Mailer, “An Appeal to Lillian Hellman and Mary McCarthy,” 5/11/80 New York Times.
1 See Norman Mailer, “An Appeal to Lillian Hellman and Mary McCarthy,” 5/11/80 New York Times.
2
DOJ-OGR-00002354
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