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544 KB
Extraction Summary
5
People
2
Organizations
0
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing / court document (motion or memorandum of law)
File Size:
544 KB
Summary
This is page 6 of a legal filing (Document 124) from the Ghislaine Maxwell case (1:20-cr-00330-AJN), dated January 25, 2021. The defense argues that the indictment is unconstitutionally vague because it uses interchangeable terms for victims (e.g., 'Minor Victim-1' vs 'girls') and fails to provide specific dates or locations for alleged crimes occurring 27 years prior. The text lists specific vague allegations such as 'befriend,' 'groomed,' and 'took Minor Victim -2 to a movie' to illustrate the difficulty in preparing a defense.
People (5)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Ms. Maxwell |
The subject of the legal defense argument; claiming inability to prepare defense due to vague indictment.
|
| Jeffrey Epstein | Associate/Alleged Perpetrator |
Mentioned in the phrase "Epstein's minor victims".
|
| Minor Victim-1 | Alleged Victim |
Pseudonym for an accuser mentioned in the indictment.
|
| Minor Victim-2 | Alleged Victim |
Pseudonym for an accuser; allegedly taken to a movie by Maxwell.
|
| Minor Victim-3 | Alleged Victim |
Pseudonym for an accuser mentioned in the indictment.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| DOJ |
Department of Justice (implied by Bates stamp DOJ-OGR).
|
|
| District Court |
Case 1:20-cr-00330-AJN (Southern District of New York).
|
Timeline (2 events)
Unknown (referenced as 27 years in the past)
Alleged sexual abuse
Unknown (Document explicitly complains about lack of location)
Ms. Maxwell
Minor Victims
Relationships (2)
Indictment alleges Maxwell 'took Minor Victim -2 to a movie'
Text refers to 'Epstein’s minor victims'
Key Quotes (4)
"The inconsistent and interchangeable use of seemingly defined alleged victims... prevents Ms. Maxwell from knowing what alleged conduct with what alleged person formed the basis of this Indictment"Source
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Quote #1
"The discovery provides to Ms. Maxwell provides no information about when and where the alleged instances of sexual abuse took place."Source
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Quote #2
"Because there are no dates provided, other than a three-year period beginning (perhaps) 27 years in the past, Ms. Maxwell cannot properly investigate where she and other witnesses were"Source
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Quote #3
"took Minor Victim -2 to a movie"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,500 characters)
Case 1:20-cr-00330-AJN Document 124 Filed 01/25/21 Page 6 of 8
• "some of the minor girls" ¶ 2;
• "multiple minor girls" ¶ 4;
• "Epstein’s minor victims" ¶ 4a;
• "a minor victim" ¶ 4b;
• "Among the victims ... were minor victims identified herein as Minor Victim-1,
Minor Victim-2, and Minor Victim-3." ¶ 7; and
Minor Victim-2, and Minor Victim-3." ¶ 7; and
• "engaged in the following acts, among others, with respect to minor victims...."
¶ 7.
¶ 7.
The inconsistent and interchangeable use of seemingly defined alleged victims, i.e.,
Minor Victim-1, with generic undefined "victims," "minor victims," and "girls," prevents Ms.
Maxwell from knowing what alleged conduct with what alleged person formed the basis of this
Indictment and allows for multiple variances of proof at any trial.
Random acts are disbursed throughout the indictment, some tied to generic alleged
"victims" other to a defined alleged "Minor Victim:"
• "befriend" ¶ 4a;
• "being present" ¶ 7a;
• "groomed" ¶ 7a;
• "undressing" ¶ 7a; and
• "took Minor Victim -2 to a movie" ¶ 7b.
The discovery provides to Ms. Maxwell provides no information about when and where
the alleged instances of sexual abuse took place. Because there are no dates provided, other than
a three-year period beginning (perhaps) 27 years in the past, Ms. Maxwell cannot properly
investigate where she and other witnesses were when the alleged crime supposedly occurred.
And because the crimes alleged in Counts One through Four are based largely on vaguely stated,
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