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609 KB

Extraction Summary

8
People
3
Organizations
1
Locations
2
Events
2
Relationships
3
Quotes

Document Information

Type: Legal court filing / order denying motion
File Size: 609 KB
Summary

This document is page 44 of a court order (Case 1:20-cr-00330-AJN) filed on April 29, 2022, denying the Defendant's (Ghislaine Maxwell) Rule 29 motion to vacate convictions. The court rejects arguments regarding prejudice due to absent deceased witnesses (including Jeffrey Epstein, his mother, Michael Casey, and Detective Joseph Recarey) and claims of pre-indictment delay. The text references evidence establishing the Defendant's close work with an individual named Markham on a manual and checklists.

People (8)

Name Role Context
The Defendant Defendant
Ghislaine Maxwell (implied by case citation Maxwell, 534 F. Supp. 3d); subject of the Rule 29 motion denial.
Juan Alessi Witness
Provided testimony at trial.
Markham Associate
Worked closely with the Defendant to create a manual/checklists.
Jeffrey Epstein Deceased potential witness
Mentioned as an absent witness causing alleged prejudice.
Epstein's mother Deceased potential witness
Mentioned as an absent witness causing alleged prejudice.
Jane Victim/Witness
Mentioned in relation to her talent agent.
Michael Casey Talent Agent
Jane's talent agent; listed as a deceased potential witness.
Joseph Recarey Detective
Palm Beach Police Department Detective; listed as a deceased potential witness.

Organizations (3)

Name Type Context
Palm Beach Police Department
Employer of Detective Joseph Recarey.
The Court
Judicial body issuing the order.
The Government
Prosecution.

Timeline (2 events)

2022-04-29
Court denies the Defendant's Rule 29 motion to vacate convictions.
Court
Unknown (Past)
Creation of a manual and checklists.
Unknown

Locations (1)

Location Context
Location of the Police Department mentioned.

Relationships (2)

The Defendant Professional/Collaborative Markham
Worked closely together to create a manual and checklists.
Jane Client/Agent Michael Casey
Text refers to 'Jane's talent agent Michael Casey'.

Key Quotes (3)

"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"
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
"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-00021027.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,014 characters)

Case 22-1426, Document 58, 02/28/2023, 3475901, Page201 of 221
A-401
Case 1:20-cr-00330-AJN 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
44
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