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669 KB
Extraction Summary
4
People
3
Organizations
0
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal filing / court document (government response/motion in limine)
File Size:
669 KB
Summary
This page from a legal filing (Document 397 in Case 1:20-cr-00330-PAE, the Ghislaine Maxwell trial) outlines the Government's argument for admitting evidence of rape. The prosecution rebuts defense claims that such evidence is irrelevant or overly inflammatory (Rule 403), asserting that the victims' testimony is necessary to explain the complex, multi-year relationships between the defendant, Epstein, and the victims. The text clarifies that the Indictment charges conspiracies for 'sexual activity' and 'commercial sex acts,' not merely 'sexualized massages' as the defense suggested.
People (4)
| Name | Role | Context |
|---|---|---|
| The Defendant | Accused |
Ghislaine Maxwell (implied by Case 1:20-cr-00330-PAE); accused of conspiring to arrange sexual activity and commercia...
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| Epstein | Co-conspirator / Abuser |
Mentioned in the context of ongoing relationships with the defendant and victims; defense argues the indictment doesn...
|
| Victims | Witnesses |
Their accounts are deemed necessary to complete the story of the crime; described as having complex relationships wit...
|
| The Jury | Adjudicator |
The body responsible for deciding on the defendant's knowledge and involvement.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government |
Arguing that indictments do not contain all evidence and defending the inclusion of rape testimony.
|
|
| The Defense |
Arguing that rape evidence is irrelevant and inflammatory (Rule 403).
|
|
| DOJ-OGR |
Source of the document (stamped in footer).
|
Relationships (2)
Mention of 'ongoing relationships between the defendant, Epstein, and the victims'
Mention of 'complex relationships between victims and their abusers'
Key Quotes (5)
"The ongoing relationships between the defendant, Epstein, and the victims is directly relevant"Source
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Quote #1
"The defendant repeatedly claims that there is no evidence she participated in or was aware of a rape specifically"Source
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Quote #2
"Indictments are not documents that contain all of the Government’s evidence"Source
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Quote #3
"The Indictment charges the defendant with conspiracies to arrange for “sexual activity”... and “a commercial sex act”"Source
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Quote #4
"Testimony from victims in sex crimes trials can be very emotional when describing their abuse and the perpetrator."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (1,968 characters)
Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 81 of 84
intention that they would engage in illegal or commercial sex acts, and conspiring to do, and aiding
and abetting, the same. These events occurred during an ongoing course of conduct, in some
instances during multi-year relationships. The ongoing relationships between the defendant,
Epstein, and the victims is directly relevant, and the victims’ accounts of these events are necessary
to complete the story of the crime on trial. Indeed, given the complex relationships between
victims and their abusers, these events are integral to the relationships that will be at the heart of
the trial. The defendant repeatedly claims that there is no evidence she participated in or was
aware of a rape specifically (Def. Mot. 11 at 1-2), but defense arguments about her knowledge and
involvement are for the jury.
and abetting, the same. These events occurred during an ongoing course of conduct, in some
instances during multi-year relationships. The ongoing relationships between the defendant,
Epstein, and the victims is directly relevant, and the victims’ accounts of these events are necessary
to complete the story of the crime on trial. Indeed, given the complex relationships between
victims and their abusers, these events are integral to the relationships that will be at the heart of
the trial. The defendant repeatedly claims that there is no evidence she participated in or was
aware of a rape specifically (Def. Mot. 11 at 1-2), but defense arguments about her knowledge and
involvement are for the jury.
The defense argues that the Indictment does not allege that Epstein raped anyone, and so
the rape is irrelevant. (Def. Mot. 11 at 2). That is a non sequitur. Indictments are not documents
that contain all of the Government’s evidence, and the defense cites no authority for the puzzling
argument that witnesses cannot testifying using words that are not contained in an indictment. To
the extent the defense understands the Indictment to allege only conspiracies to arrange for
sexualized massages for Epstein (id. at 3), the defense is mistaken. The Indictment charges the
defendant with conspiracies to arrange for “sexual activity” (Indictment ¶¶ 12, 18) and “a
commercial sex act” (Id. ¶ 24).
the rape is irrelevant. (Def. Mot. 11 at 2). That is a non sequitur. Indictments are not documents
that contain all of the Government’s evidence, and the defense cites no authority for the puzzling
argument that witnesses cannot testifying using words that are not contained in an indictment. To
the extent the defense understands the Indictment to allege only conspiracies to arrange for
sexualized massages for Epstein (id. at 3), the defense is mistaken. The Indictment charges the
defendant with conspiracies to arrange for “sexual activity” (Indictment ¶¶ 12, 18) and “a
commercial sex act” (Id. ¶ 24).
The defense also argues that evidence of a rape does not satisfy Rule 403 balancing,
because evidence of a rape is “highly emotional and inflammatory.” (Def. Mot. 11 at 3). This
conclusory claim is insufficient to show prejudice to the defense. Testimony from victims in sex
crimes trials can be very emotional when describing their abuse and the perpetrator. But that
because evidence of a rape is “highly emotional and inflammatory.” (Def. Mot. 11 at 3). This
conclusory claim is insufficient to show prejudice to the defense. Testimony from victims in sex
crimes trials can be very emotional when describing their abuse and the perpetrator. But that
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DOJ-OGR-00005864
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