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723 KB

Extraction Summary

3
People
2
Organizations
0
Locations
3
Events
2
Relationships
4
Quotes

Document Information

Type: Court filing (legal brief/memorandum)
File Size: 723 KB
Summary

This document is page 13 of a legal filing (Document 100) from December 18, 2020, in the case against Ghislaine Maxwell. The Government argues that contrary to the Defense's claims, the case is strong because three independent victims will testify to the specific grooming techniques used by Maxwell and Epstein, including the use of massage to transition to sexual acts and the manipulation of minors by an adult woman. The text notes that these accounts corroborate one another by describing the same course of conduct.

People (3)

Name Role Context
The Defendant Accused
Ghislaine Maxwell (implied by Case 1:20-cr-00330); accused of grooming, befriending victims, and normalizing sexual a...
Epstein Co-conspirator
Described as running a criminal scheme to sexually abuse minors; used specific grooming techniques.
Three different victims Witnesses/Victims
Minors at the time of abuse; prepared to provide detailed testimony describing the defendant's role.

Organizations (2)

Name Type Context
The Government
Arguing against the defense's motion; asserting the strength of witness testimony.
The Defense
Arguing the case is weak due to age of events and lack of corroborating evidence.

Timeline (3 events)

2020-12-18
Filing of Document 100 in Case 1:20-cr-00330-AJN
Court Record
Government Defense
25 years ago (approximate)
Events of alleged abuse and grooming.
Unknown
Unknown (Original Hearing)
Original bail hearing where defense argued the case was weak.
Court
Defense Government

Relationships (2)

The Defendant Co-conspirators Epstein
Described as using the 'same techniques' in a 'criminal scheme'.
The Defendant Abuser/Victim Three different victims
Defendant 'befriended' them, asked detailed questions, and 'manipulated' them into abusive situations.

Key Quotes (4)

"Three different victims are prepared to provide detailed testimony describing the defendant’s role in Epstein’s criminal scheme to sexually abuse them as minors."
Source
DOJ-OGR-00002174.jpg
Quote #1
"Each victim will describe how the defendant befriended her, asked detailed questions about her life, and then normalized sexual activity around Epstein."
Source
DOJ-OGR-00002174.jpg
Quote #2
"Each victim will describe the use of massage as a technique to transition into sexual activity."
Source
DOJ-OGR-00002174.jpg
Quote #3
"Each victim will describe how the presence of an adult woman manipulated her into entering an abusive situation."
Source
DOJ-OGR-00002174.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (2,162 characters)

Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 13 of 36
Further, and as set forth below, those victims’ accounts are corroborated by other evidence, including contemporary documents and other witnesses.
In challenging this factor, the defense essentially restates its prior arguments on this score. At the original hearing, the defense argued that the Government’s case was weak because it rested heavily on witness testimony regarding events from 25 years ago. (See Dkt. 18 at 19; Tr. 64-65). Having received and reviewed the discovery, the defense now contends the Government’s corroborating evidence—some of which the Motion itself identifies—is insufficient and reiterates defense complaints that the discovery does not include other types of evidence.1 (See Mot. at 30-33).
None of the defense arguments on this score changes the calculus for this factor. Three different victims are prepared to provide detailed testimony describing the defendant’s role in Epstein’s criminal scheme to sexually abuse them as minors. As demonstrated by the information outlined in the Indictment, these accounts corroborate each other by independently describing the same techniques used by the defendant and Epstein to groom and entice minor girls to engage in sex acts. Each victim will describe how the defendant befriended her, asked detailed questions about her life, and then normalized sexual activity around Epstein. Each victim will describe the use of massage as a technique to transition into sexual activity. Each victim will describe how the presence of an adult woman manipulated her into entering an abusive situation. In other words, this is a case that involves multiple witnesses describing the same course of conduct, substantially corroborating each other.
____________________
1 At the initial bail hearing, the defendant also raised a series of legal challenges she intended to make on the face of the Indictment, all of which she contended weighed in favor of granting bail. After receiving discovery, the defense now appears to have abandoned those arguments, at least insofar as they pertain to the issue of bail.
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DOJ-OGR-00002174

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