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753 KB
Extraction Summary
3
People
4
Organizations
1
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing (government memorandum of law)
File Size:
753 KB
Summary
This is page 168 of a legal filing (Document 204) from the case United States v. Ghislaine Maxwell, filed on April 16, 2021. The Government argues that perjury counts (Counts Five and Six) should be tried jointly with the sex trafficking counts (Counts One through Four) because they involve the same evidence and separating them would waste judicial resources and traumatize victims by forcing them to testify twice. The text explicitly references Epstein's scheme to abuse underage girls and Maxwell's alleged participation in recruiting girls for sexual massages.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Referred to as 'The defendant' and 'Maxwell'. The text argues against severing her perjury charges from her other cha...
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| Jeffrey Epstein | Co-conspirator (Deceased) |
Mentioned in the context of 'Epstein’s scheme to abuse underage girls'.
|
| Unnamed Victims | Victims/Witnesses |
Referred to as 'victims of sexual abuse' and 'underage girls' who would have to testify.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Government |
The entity arguing for the joinder of counts.
|
|
| The Court |
The judicial body hearing the case.
|
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| S.D.N.Y. |
Southern District of New York, cited in case law (United States v. Hester).
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| DOJ-OGR |
Department of Justice - Office of Government Relations (likely), appears in footer bates stamp.
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Timeline (2 events)
Unknown
Locations (1)
| Location | Context |
|---|---|
|
New York (Southern District)
|
Relationships (2)
Text refers to 'Epstein’s scheme to abuse underage girls, and Maxwell’s participation therein'.
Text discusses testimony regarding 'massages resulting in sexual abuse' and 'scheme to recruit underage girls'.
Key Quotes (3)
"Severing the counts would waste judicial resources by requiring a second trial at which the Government would offer similar proof, including by calling the same victims of sexual abuse to testify again at a second trial."Source
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Quote #1
"In particular, victim testimony and related evidence offered to prove the existence of Epstein’s scheme to abuse underage girls, and Maxwell’s participation therein, will also provide much of the evidence demonstrating the falsity of the statements charged in Count Five."Source
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Quote #2
"denying interacting with underage girls and a denying a “scheme to recruit underage girls for sexual massages”"Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,232 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 168 of 239
often will suffice to cure any risk of prejudice and permit joinder.” Page, 657 F.3d at 129 (internal
quotation marks omitted).
quotation marks omitted).
B. Discussion
The perjury counts should be tried jointly with Counts One through Four. The offenses are
of similar character, are logically connected and will be proved through much of the same evidence
because the perjury counts concern at least some of the same conduct relevant to the crimes
charged in Counts One through Four and, as such, are properly joined. See generally Potamitis,
739 F.2d at 791. Severing the counts would waste judicial resources by requiring a second trial at
which the Government would offer similar proof, including by calling the same victims of sexual
abuse to testify again at a second trial. The defendant has identified no prejudice sufficient to
justify imposing that burden on the victims, the Court, and the Government.
of similar character, are logically connected and will be proved through much of the same evidence
because the perjury counts concern at least some of the same conduct relevant to the crimes
charged in Counts One through Four and, as such, are properly joined. See generally Potamitis,
739 F.2d at 791. Severing the counts would waste judicial resources by requiring a second trial at
which the Government would offer similar proof, including by calling the same victims of sexual
abuse to testify again at a second trial. The defendant has identified no prejudice sufficient to
justify imposing that burden on the victims, the Court, and the Government.
First, the Government expects to prove the offenses charged in Counts One through Four
and those charged in Counts Five and Six with much of the same evidence. See United States v.
Hester, No. 19 Cr. 324 (NSR), 2020 WL 3483702, at *21 (S.D.N.Y. June 26, 2020) (“Notably, the
fact that evidence of the crime charged in one count may be admissible in the Government’s direct
case in the trial of the other will typically defeat the need to severe the counts.”). At trial, some of
the most critical evidence that the defendant committed the offenses charged in Counts One
through Four will also form the crux of the Government’s proof of the falsity of the defendant’s
deposition testimony. In particular, victim testimony and related evidence offered to prove the
existence of Epstein’s scheme to abuse underage girls, and Maxwell’s participation therein, will
also provide much of the evidence demonstrating the falsity of the statements charged in Count
Five. Compare, e.g., Indictment ¶ 4(c), (e) (discussing massages resulting in sexual abuse), with
id. ¶ 21 (denying interacting with underage girls and a denying a “scheme to recruit underage girls
for sexual massages”). Similarly, aspects of that proof, such as testimony regarding the sexualized
and those charged in Counts Five and Six with much of the same evidence. See United States v.
Hester, No. 19 Cr. 324 (NSR), 2020 WL 3483702, at *21 (S.D.N.Y. June 26, 2020) (“Notably, the
fact that evidence of the crime charged in one count may be admissible in the Government’s direct
case in the trial of the other will typically defeat the need to severe the counts.”). At trial, some of
the most critical evidence that the defendant committed the offenses charged in Counts One
through Four will also form the crux of the Government’s proof of the falsity of the defendant’s
deposition testimony. In particular, victim testimony and related evidence offered to prove the
existence of Epstein’s scheme to abuse underage girls, and Maxwell’s participation therein, will
also provide much of the evidence demonstrating the falsity of the statements charged in Count
Five. Compare, e.g., Indictment ¶ 4(c), (e) (discussing massages resulting in sexual abuse), with
id. ¶ 21 (denying interacting with underage girls and a denying a “scheme to recruit underage girls
for sexual massages”). Similarly, aspects of that proof, such as testimony regarding the sexualized
141
DOJ-OGR-00003102
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