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718 KB
Extraction Summary
4
People
2
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Court filing / legal opinion (page 40 of 45)
File Size:
718 KB
Summary
This document is page 40 of a court filing (Case 1:20-cr-00330-PAE) from April 29, 2022, likely rejecting a motion by Ghislaine Maxwell. The text discusses the defense's failure to prove that missing evidence (financial records, phone records, and pre-9/11 flight manifests) prejudiced the case. The court notes that the defense's claim that these missing records would show an absence of incriminating connections (payments, calls to victims) is purely speculative.
People (4)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant |
Subject of the court ruling (Ghislaine Maxwell, based on case number 1:20-cr-00330), arguing that missing evidence pr...
|
| Jeffrey Epstein | Associate/Employer |
Mentioned regarding his habits, residences, and potential payments to the Defendant.
|
| Lynn Fontanilla | Witness / Housekeeper |
Described as a live-in housekeeper for Epstein in New York who could have testified about habits.
|
| The Countess | Alleged Author |
Person alleged by the defense to have created the 'household manual' instead of the Defendant.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Court |
The entity issuing the opinion and addressing the evidence.
|
|
| The Government |
Elicited testimony at trial regarding flight manifests.
|
Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
Location where Lynn Fontanilla worked as a live-in housekeeper for Epstein.
|
Relationships (2)
Lynn Fontanilla described as 'a live-in housekeeper for Epstein in New York'
Defense argument that the manual was created by 'the Countess,' not the Defendant
Key Quotes (4)
"household manual was created by 'the Countess,' not the Defendant"Source
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Quote #1
"None of these identified pieces of alleged evidence satisfies the Defendant’s burden of proving actual and substantial prejudice."Source
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Quote #2
"flight manifests from before September 11, 2001, were far less detailed than modern manifests."Source
DOJ-OGR-00010406.jpg
Quote #3
"The Defendant’s motion presumes that each piece of missing evidence would have favored her... But this presumption is purely speculative."Source
DOJ-OGR-00010406.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,093 characters)
Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 40 of 45
2000s that could have testified the household manual was created by “the Countess,” not the
Defendant; and Lynn Fontanilla, a live-in housekeeper for Epstein in New York that could have
testified about the Defendant’s and Epstein’s habits.
Defendant; and Lynn Fontanilla, a live-in housekeeper for Epstein in New York that could have
testified about the Defendant’s and Epstein’s habits.
None of these identified pieces of alleged evidence satisfies the Defendant’s burden of
proving actual and substantial prejudice. The Court addresses first the documentary evidence.
proving actual and substantial prejudice. The Court addresses first the documentary evidence.
First, the Defendant does not attest, or even suggest, what the absent documents are likely to
show. Though the Defendant would herself be best positioned to explain her own financial
transactions (or the lack thereof), her brief does not suggest what the absent financial records
would have shown. Similarly, the Defendant does not identify what would have been shown in
the absent phone records. The same is true of the flight records that the Defendant argues were
missing. At trial, the Government elicited testimony that flight manifests from before September
11, 2001, were far less detailed than modern manifests. E.g., Trial Tr. at 2518–22. The
Defendant can therefore only speculate that more accurate records ever existed. The location
and appearance of Epstein’s residences were also the source of significant testimony at trial. The
Defendant does not explain what additional information would have been contained in official
property records.
show. Though the Defendant would herself be best positioned to explain her own financial
transactions (or the lack thereof), her brief does not suggest what the absent financial records
would have shown. Similarly, the Defendant does not identify what would have been shown in
the absent phone records. The same is true of the flight records that the Defendant argues were
missing. At trial, the Government elicited testimony that flight manifests from before September
11, 2001, were far less detailed than modern manifests. E.g., Trial Tr. at 2518–22. The
Defendant can therefore only speculate that more accurate records ever existed. The location
and appearance of Epstein’s residences were also the source of significant testimony at trial. The
Defendant does not explain what additional information would have been contained in official
property records.
Second, even if more detail of the contents of these documents were presented, the
Defendant fails to show why the evidence, if admitted at trial, would have benefitted her case.
The Defendant’s motion presumes that each piece of missing evidence would have favored her:
an absence of payments by Epstein to the Defendant, an absence of phone calls from the
Defendant to victims, an absence of the victims on detailed flight manifests. But this
presumption is purely speculative. Each piece of evidence may very well have further
substantiated the Government’s case. Because the Defendant carries the burden of proof, she is
Defendant fails to show why the evidence, if admitted at trial, would have benefitted her case.
The Defendant’s motion presumes that each piece of missing evidence would have favored her:
an absence of payments by Epstein to the Defendant, an absence of phone calls from the
Defendant to victims, an absence of the victims on detailed flight manifests. But this
presumption is purely speculative. Each piece of evidence may very well have further
substantiated the Government’s case. Because the Defendant carries the burden of proof, she is
40
DOJ-OGR-00010406
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