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Extraction Summary

8
People
3
Organizations
1
Locations
3
Events
3
Relationships
4
Quotes

Document Information

Type: Court opinion/order
File Size: 679 KB
Summary

This document is page 44 of a court order denying Ghislaine Maxwell's Rule 29 motion and motion to vacate convictions. The court rejects arguments regarding prejudice due to deceased witnesses (including Jeffrey Epstein, his mother, Michael Casey, and Joseph Recarey) and pre-indictment delay. The text references evidence GX-424, an email chain showing Maxwell worked closely with an individual named Markham to create a household manual.

People (8)

Name Role Context
Ghislaine Maxwell Defendant
Subject of the court order; referred to as 'the Defendant'; motion to vacate convictions denied.
Juan Alessi Witness
Former employee whose testimony was presented at trial.
Markham Associate
Worked closely with the Defendant to create a manual and checklists.
Jeffrey Epstein Deceased Potential Witness
Cited by defense as an absent witness causing prejudice.
Epstein's Mother Deceased Potential Witness
Cited by defense as an absent witness causing prejudice.
Michael Casey Deceased Potential Witness
Jane's talent agent; cited by defense as an absent witness.
Jane Victim/Witness
Mentioned in relation to her talent agent, Michael Casey.
Joseph Recarey Deceased Potential Witness
Palm Beach Police Department Detective; cited by defense as an absent witness.

Organizations (3)

Name Type Context
Palm Beach Police Department
Employer of Detective Joseph Recarey.
The Government
Prosecution; argued against the Defendant's claims of pre-indictment delay.
The Court
Judicial body issuing the order and denying the motions.

Timeline (3 events)

2022-04-29
Court Order Filing
Court Docket
Unknown (Past)
Creation of Household Manual
Unknown
Unknown (Past)
Trial
Court
Ghislaine Maxwell Juan Alessi Jury Government

Locations (1)

Location Context
Location of the Police Department mentioned.

Relationships (3)

Ghislaine Maxwell Professional/Co-worker Markham
Email chain indicates they worked closely to create a manual.
Michael Casey Professional (Agent/Client) Jane
Described as 'Jane’s talent agent Michael Casey'.
Described as 'Palm Beach Police Department Detective'.

Key Quotes (4)

"Defendant worked closely with Markham to create the manual and provided specific content, such as the checklists, to be included."
Source
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Quote #1
"The Court therefore denies her motion to vacate her convictions on this basis."
Source
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Quote #2
"She has not satisfied either element required for a claim of pre-indictment delay..."
Source
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Quote #3
"The Court denies the Defendant’s Rule 29 motion because the jury’s guilty verdicts were supported by the witness testimony and documentary evidence presented at trial."
Source
DOJ-OGR-00010410.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,944 characters)

Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 44 of 45
would have credited this vague testimony about an unnamed individual over the evidence
presented at trial, including the testimony of Juan Alessi and an email chain between the
Defendant and Markham that indicates that the Defendant worked closely with Markham to
create the manual and provided specific content, such as the checklists, to be included. See GX-
424.
Finally, the Defendant refers to her prior briefing in which she alleged substantial
prejudice because of the absence of other deceased potential witnesses, including Epstein,
Epstein’s mother, Jane’s talent agent Michael Casey, and Palm Beach Police Department
Detective Joseph Recarey. See Dkt. No. 138 at 8–11. The Court has previously considered and
rejected the Defendant’s claim of prejudice based on these absent witnesses. Maxwell, 534 F.
Supp. 3d at 317. The Defendant points to no development at trial that she believes should alter
the Court’s conclusion, nor is the Court aware of any such reason for reconsideration.
The Defendant’s reply brief devotes just a single sentence to her claim of pre-indictment
delay and does not address any of the defects identified by the Government. She has not
satisfied either element required for a claim of pre-indictment delay, as she has not demonstrated
that the Government improperly delayed prosecution nor that she suffered actual and substantial
prejudice from such delay. The Court therefore denies her motion to vacate her convictions on
this basis.
V. Conclusion
For the foregoing reasons, the Court denies the Defendant’s Rule 29 motion because the
jury’s guilty verdicts were supported by the witness testimony and documentary evidence
presented at trial. The Court denies the Defendant’s motion based on constructive amendment or
variance because the jury instructions, the Government’s evidence at trial, and summation all
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