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690 KB
Extraction Summary
4
People
3
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal court filing (case 1:20-cr-00330-pae - united states v. ghislaine maxwell)
File Size:
690 KB
Summary
This document is page 152 of a legal filing (Document 204) from the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text argues against dismissing a perjury count, stating that the defendant's denial of knowledge regarding Epstein's scheme to recruit underage girls for sexual massages was not due to fundamental ambiguity in the questioning. It includes a transcript excerpt from a deposition where Giuffre's counsel asks the defendant to list girls under 18 she brought to Epstein's house, to which Mr. Pagliuca objects.
People (4)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Subject of inquiry |
Accused of having a scheme to recruit underage girls for sexual massages.
|
| The Defendant | Accused |
Ghislaine Maxwell (implied by case number). Accused of perjury regarding knowledge of Epstein's scheme and recruiting...
|
| Giuffre | Plaintiff/Victim |
Mentioned as 'Giuffre's counsel' who conducted the deposition questioning.
|
| Mr. Pagliuca | Defense Attorney |
Lawyer objecting to the question during the deposition.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government |
Referring to the prosecution's evidence in the criminal case.
|
|
| DOJ-OGR |
Department of Justice - Office of General Review (indicated in Bates stamp).
|
|
| 2d Cir. |
Second Circuit Court of Appeals (cited in legal precedents).
|
Timeline (2 events)
Unknown (Past)
Locations (1)
| Location | Context |
|---|---|
|
Location where the defendant allegedly brought underage girls.
|
Relationships (2)
Questioning regarding defendant bringing underage girls to Epstein's house.
Giuffre's counsel questioning the defendant in a deposition.
Key Quotes (4)
"did Jeffrey Epstein have a scheme to recruit underage girls for sexual massages . . . [i]f you know?"Source
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Quote #1
"Can you list for me all the girls that you have met and brought to Jeffrey Epstein’s house that were under the age of 18?"Source
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Quote #2
"the defendant “consistently denied” knowledge of Epstein’s scheme"Source
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Quote #3
"ambiguity was not “fundamental.”"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,999 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 152 of 239
the victims specified in the Indictment about sexualized massages the victims provided to Epstein,
conduct that obviously predated the deposition. See Indictment ¶ 7(a), (c). In context, and with an
understanding of the Government’s other evidence, a rational juror could readily conclude that the
question “did Jeffrey Epstein have a scheme to recruit underage girls for sexual massages . . . [i]f
you know?” had a clear meaning, and more important for purposes of the instant motion, any
ambiguity was not “fundamental.” Cf. Triumph Capital Grp., Inc., 237 F. App’x at 628
(concluding that an answer about “this arrangement” was not fundamentally ambiguous).
conduct that obviously predated the deposition. See Indictment ¶ 7(a), (c). In context, and with an
understanding of the Government’s other evidence, a rational juror could readily conclude that the
question “did Jeffrey Epstein have a scheme to recruit underage girls for sexual massages . . . [i]f
you know?” had a clear meaning, and more important for purposes of the instant motion, any
ambiguity was not “fundamental.” Cf. Triumph Capital Grp., Inc., 237 F. App’x at 628
(concluding that an answer about “this arrangement” was not fundamentally ambiguous).
Nor is there any basis to dismiss the count now based on the defendant’s professed
confusion or denial of knowledge of the scheme’s existence. A defendant may commit perjury by
falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d
617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde,
740 F. Supp. 2d at 410-11. Viewing the question and answer “in the context of the line of
questioning as a whole,” the defendant “consistently denied” knowledge of Epstein’s scheme,
Markiewicz, 978 F.2d at 810, and a jury could conclude that the “question was not fundamentally
ambiguous—and thus that [the defendant], understanding the question, lied.” See Sampson, 898
F.3d at 307; cf. Indictment ¶¶ 4(e) 11(c)-(d), 17(c)-(d) (discussing use of massage as part of the
sexual abuse scheme).
confusion or denial of knowledge of the scheme’s existence. A defendant may commit perjury by
falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d
617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde,
740 F. Supp. 2d at 410-11. Viewing the question and answer “in the context of the line of
questioning as a whole,” the defendant “consistently denied” knowledge of Epstein’s scheme,
Markiewicz, 978 F.2d at 810, and a jury could conclude that the “question was not fundamentally
ambiguous—and thus that [the defendant], understanding the question, lied.” See Sampson, 898
F.3d at 307; cf. Indictment ¶¶ 4(e) 11(c)-(d), 17(c)-(d) (discussing use of massage as part of the
sexual abuse scheme).
Second, later in the deposition, Giuffre’s counsel asked the defendant a series of questions
in an attempt to identify other underage girls that the defendant met and brought to Epstein.
Specifically:
in an attempt to identify other underage girls that the defendant met and brought to Epstein.
Specifically:
Q. Can you list for me all the girls that you have met and brought to
Jeffrey Epstein’s house that were under the age of 18?
Jeffrey Epstein’s house that were under the age of 18?
MR. PAGLIUCA: Objection to the form and foundation.
125
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