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735 KB
Extraction Summary
9
People
4
Organizations
2
Locations
2
Events
4
Relationships
5
Quotes
Document Information
Type:
Legal filing (court order/opinion)
File Size:
735 KB
Summary
This page from a court order (Case 1:20-cr-00330-PAE) rejects the Defendant's (Ghislaine Maxwell) argument that she was prejudiced by the inability to call deceased witnesses, specifically two architects and a housekeeper. The court rules that this argument is speculative and unsubstantiated because other available witnesses, including Juan Alessi, Larry Visoski, and David Rodgers, testified at trial covering similar topics regarding Epstein's residences, renovations, and private aircraft.
People (9)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Referred to as 'the Defendant'; filing argues she failed to establish prejudice regarding absent witnesses.
|
| Jeffrey Epstein | Deceased Financier |
Mentioned regarding his residences, renovations, townhouse, and employees.
|
| Juan Alessi | Witness/Former Employee |
Testified at trial regarding employment at residences.
|
| Larry Visoski | Witness/Pilot |
Testified at trial regarding flying the private airplane.
|
| David Rodgers | Witness/Former Employee |
Testified at trial.
|
| King | Legal Citation Subject |
Referenced in United States v. King case citation.
|
| Long | Legal Citation Subject |
Referenced in United States v. Long case citation.
|
| Unnamed Architects | Deceased Potential Witnesses |
Two architects the defense claims could have established renovation timelines.
|
| Unnamed Housekeeper | Deceased Potential Witness |
Live-in housekeeper the defense claims could have testified about Maxwell's presence.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States District Court |
Implied by case number and S.D.N.Y. citation.
|
|
| Second Circuit Court of Appeals |
Cited as '2d Cir.' in case law.
|
|
| S.D.N.Y. |
Southern District of New York, cited in case law.
|
|
| DOJ-OGR |
Department of Justice Office of Government Information Services (referenced in footer stamp).
|
Timeline (2 events)
Locations (2)
| Location | Context |
|---|---|
|
Location of Epstein's townhouse.
|
|
|
General reference to properties where staff worked and renovations occurred.
|
Relationships (4)
Discussion of time Defendant spent with Epstein at his townhouse.
Listed as witness who testified about working at residences.
Listed as witness who testified about flying private airplane.
Listed as witness who testified at trial.
Key Quotes (5)
"the Defendant largely speculates about the contents of these deceased witnesses’ absent testimony."Source
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Quote #1
"the two architect witnesses “could have established” the timeline for Epstein’s residences and renovations"Source
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Quote #2
"no prejudice where there is “no way of knowing what [an absent witness’s] testimony would have been”"Source
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Quote #3
"At trial, witnesses testified that Epstein employed a significant number of individuals to work at his residences, renovate those residences, or fly his private airplane."Source
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Quote #4
"Her assertion that only individuals that have since died could provide adequate testimony is entirely unsubstantiated."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,170 characters)
Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 42 of 45
defense witnesses died three years or more prior to indictment); United States v. King, 560 F.2d
122, 130 (2d Cir. 1977) (defense witness died a year prior to the indictment). Here, the
Defendant largely speculates about the contents of these deceased witnesses’ absent testimony.
She states, for example, that the two architect witnesses “could have established” the timeline for
Epstein’s residences and renovations at each but does not say what that timeline is. Maxwell Br.
at 29. Similarly, the Defendant states that Epstein’s live-in housekeeper could have testified that
the Defendant spent only limited time with Epstein at his townhouse in New York but provides
little basis or detail for that anticipated testimony. As with the documentary evidence above,
such speculation, with the apparent presumption that absent evidence would necessarily favor the
Defendant, is insufficient to establish actual prejudice. See United States v. Long, 697 F. Supp.
651, 657 (S.D.N.Y. 1988) (no prejudice where there is “no way of knowing what [an absent
witness’s] testimony would have been”).
122, 130 (2d Cir. 1977) (defense witness died a year prior to the indictment). Here, the
Defendant largely speculates about the contents of these deceased witnesses’ absent testimony.
She states, for example, that the two architect witnesses “could have established” the timeline for
Epstein’s residences and renovations at each but does not say what that timeline is. Maxwell Br.
at 29. Similarly, the Defendant states that Epstein’s live-in housekeeper could have testified that
the Defendant spent only limited time with Epstein at his townhouse in New York but provides
little basis or detail for that anticipated testimony. As with the documentary evidence above,
such speculation, with the apparent presumption that absent evidence would necessarily favor the
Defendant, is insufficient to establish actual prejudice. See United States v. Long, 697 F. Supp.
651, 657 (S.D.N.Y. 1988) (no prejudice where there is “no way of knowing what [an absent
witness’s] testimony would have been”).
Second, the Defendant fails to establish that the content of these witnesses’ testimony
could not have been introduced into trial by other means. At trial, witnesses testified that Epstein
employed a significant number of individuals to work at his residences, renovate those
residences, or fly his private airplane. Some, like Juan Alessi, Larry Visoski, and David
Rodgers, testified at trial. Still others were listed on the parties’ witness lists. The Defendant
does not explain why these witnesses’ testimony, or the testimony of those listed witnesses who
were not called, could not have supplied the same information that she seeks from individuals
who were unavailable to testify. Her assertion that only individuals that have since died could
provide adequate testimony is entirely unsubstantiated. Similarly, the Defendant does not
explain why evidence of construction or renovations at Epstein’s residences could not be proven
by other witness testimony or by documentary evidence.
could not have been introduced into trial by other means. At trial, witnesses testified that Epstein
employed a significant number of individuals to work at his residences, renovate those
residences, or fly his private airplane. Some, like Juan Alessi, Larry Visoski, and David
Rodgers, testified at trial. Still others were listed on the parties’ witness lists. The Defendant
does not explain why these witnesses’ testimony, or the testimony of those listed witnesses who
were not called, could not have supplied the same information that she seeks from individuals
who were unavailable to testify. Her assertion that only individuals that have since died could
provide adequate testimony is entirely unsubstantiated. Similarly, the Defendant does not
explain why evidence of construction or renovations at Epstein’s residences could not be proven
by other witness testimony or by documentary evidence.
42
DOJ-OGR-00010408
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