This document is a page from a defense motion filed on October 29, 2021, in the case against Ghislaine Maxwell. The defense argues to prohibit testimony from 'Accuser 4' identifying Maxwell as a perpetrator, claiming that in 2007 FBI interviews and subsequent civil lawsuits against Epstein, the accuser never identified Maxwell and instead identified another individual as the one who took nude photographs. The defense asserts that any current identification is the result of suggestive government procedures.
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Moving through counsel to prohibit testimony regarding identification.
|
| Accuser 4 | Witness/Victim |
Subject of the motion; interviewed by FBI in 2007; filed lawsuits against Epstein.
|
| Jeffrey Epstein | Alleged Abuser |
Subject of FBI questioning regarding abuse; defendant in civil lawsuits filed by Accuser 4.
|
| [Redacted] | FBI Agents |
Interviewed Accuser 4 on August 7, 2007.
|
| [Redacted] | Photographer |
Identified by Accuser 4 as the person who took nude photographs of her at Epstein's direction.
|
| Name | Type | Context |
|---|---|---|
| Government |
Prosecution team employing photo array procedures.
|
|
| FBI |
Contacted and interviewed Accuser 4 in 2007.
|
|
| United States Constitution |
Cited regarding due process rights.
|
| Location | Context |
|---|---|
|
Specific location mentioned where Accuser 4 claimed she did NOT interact with Maxwell.
|
"Any in-court identification is tainted by unduly suggestive photo array procedures employed by the Government that violate Ms. Maxwell’s right to due process"Source
"did not identify Ms. Maxwell as someone who recruited her, groomed her, or otherwise interacted with her in Palm Beach, Florida"Source
"She identified [REDACTED] as someone she interacted with and who took nude photographs of her at Mr. Epstein’s direction."Source
"Neither of those lawsuits mentions Ms. Maxwell."Source
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