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539 KB

Extraction Summary

5
People
3
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes

Document Information

Type: Court filing (defense motion)
File Size: 539 KB
Summary

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.

People (5)

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.

Organizations (3)

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.

Timeline (2 events)

2007-08-07
Accuser 4 interviewed by FBI Agents.
Unknown
Accuser 4 FBI Agents
2021-10-29
Document filed in Case 1:20-cr-00330-PAE.
Court
Ghislaine Maxwell's Counsel

Locations (1)

Location Context
Specific location mentioned where Accuser 4 claimed she did NOT interact with Maxwell.

Relationships (2)

Accuser 4 Accuser/Alleged Abuser Jeffrey Epstein
Accuser 4 filed lawsuits against Jeffrey Epstein.
Accuser 4 Non-identification (Defense Argument) Ghislaine Maxwell
Defense claims Accuser 4 did not identify Maxwell in 2007 interview or subsequent lawsuits.

Key Quotes (4)

"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
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Quote #1
"did not identify Ms. Maxwell as someone who recruited her, groomed her, or otherwise interacted with her in Palm Beach, Florida"
Source
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Quote #2
"She identified [REDACTED] as someone she interacted with and who took nude photographs of her at Mr. Epstein’s direction."
Source
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Quote #3
"Neither of those lawsuits mentions Ms. Maxwell."
Source
DOJ-OGR-00005741.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,345 characters)

Case 1:20-cr-00330-PAE Document 392 Filed 10/29/21 Page 4 of 8
Defendant Ghislaine Maxwell, through counsel, moves to prohibit the Government from offering testimony from Accuser 4 [REDACTED] identifying Ms. Maxwell as a perpetrator of any crime. 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 under the United States Constitution for the following reasons:
BACKGROUND
Accuser 4, [REDACTED] was first contacted by the FBI in 2007. [REDACTED] was interviewed on August 7, 2007 by Agents [REDACTED] and asked about any abuse by Jeffrey Epstein. [REDACTED]
[REDACTED] did not identify Ms. Maxwell as someone who recruited her, groomed her, or otherwise interacted with her in Palm Beach, Florida, or any other location. She identified [REDACTED] as someone she interacted with and who took nude photographs of her at Mr. Epstein’s direction. [REDACTED]
After her FBI interview, [REDACTED] represented by counsel, filed [REDACTED] lawsuits against Jeffrey Epstein [REDACTED]. Neither of those lawsuits mentions Ms. Maxwell. [REDACTED]
During her deposition in connection with the lawsuit, [REDACTED]
[REDACTED] She did not identify Ms. Maxwell as having had any role in any alleged sexual abuse or trafficking.
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