DOJ-OGR-00004726.jpg
745 KB
Extraction Summary
3
People
3
Organizations
1
Locations
5
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing (court document - government response/brief)
File Size:
745 KB
Summary
This document is page 19 of a legal filing (Case 1:20-cr-00330-PAE) filed on May 25, 2021, likely by the prosecution. It argues that the 'S2 Indictment' was filed timely and not delayed for strategic reasons, explaining that interviews with 'Minor Victim-4' were delayed until early 2021 due to COVID-19 travel constraints. The text refutes the defendant's motion to dismiss based on pre-indictment delay.
People (3)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant |
Indicted in July 2020; arguing against the S2 Indictment based on delay. (Case number 1:20-cr-00330 corresponds to Gh...
|
| Jeffrey Epstein | Co-conspirator/Indictee |
Mentioned as being indicted in 2019.
|
| Minor Victim-4 | Victim/Witness |
Interviewed in 2007 and 2020-2021; key source for the S2 Indictment.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government |
Prosecution team; conducted interviews and brought the S2 Indictment.
|
|
| USAO-SDFL |
United States Attorney's Office for the Southern District of Florida; conducted prior investigation in 2007.
|
|
| S.D.N.Y. |
Southern District of New York (referenced in case citation).
|
Timeline (5 events)
2007
Minor Victim-4 interviewed in connection with a prior investigation by USAO-SDFL.
Unknown
Late January 2021
Government conducted multiple in-person interviews with Minor Victim-4.
Unknown
Locations (1)
| Location | Context |
|---|---|
|
Jurisdiction mentioned in legal citation.
|
Relationships (2)
Government conducted interviews with Minor Victim-4 in 2020 and 2021.
Document compares indictment timelines of the defendant (2020) and Epstein (2019).
Key Quotes (3)
"Simply put, the S2 Indictment was brought in a timely manner upon the Government’s collection of evidence to support the additional charges."Source
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Quote #1
"The defendant has not established—and cannot establish—an undue delay, much less an intentional and deliberate delay caused by the Government for an improper purpose."Source
DOJ-OGR-00004726.jpg
Quote #2
"Due to travel constraints and safety concerns arising from the COVID-19 pandemic, the Government was unable to travel to meet with Minor Victim-4 until late January 2021"Source
DOJ-OGR-00004726.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,194 characters)
Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 19 of 26
time the defendant was indicted in July 2020 or at the time Jeffrey Epstein was indicted in 2019.
Specifically, although Minor Victim-4 had previously been interviewed once in or about 2007 in
connection with a prior investigation conducted by the USAO-SDFL, Minor Victim-4 did not
agree to be interviewed by the prosecution team handling this case until July 2020. The
Government then conducted two preliminary interviews with Minor Victim-4 by video
teleconference in the summer of 2020. Because of the difficult nature of the interview topics,
however, the Government was not able to fully debrief Minor Victim-4 over video. Due to travel
constraints and safety concerns arising from the COVID-19 pandemic, the Government was unable
to travel to meet with Minor Victim-4 until late January 2021, at which time the Government
conducted multiple in-person interviews with Minor Victim-4. The Government then took
additional investigative steps and sought the S2 Indictment in late March 2021, approximately two
months after concluding its debriefing of Minor Victim-4.
Specifically, although Minor Victim-4 had previously been interviewed once in or about 2007 in
connection with a prior investigation conducted by the USAO-SDFL, Minor Victim-4 did not
agree to be interviewed by the prosecution team handling this case until July 2020. The
Government then conducted two preliminary interviews with Minor Victim-4 by video
teleconference in the summer of 2020. Because of the difficult nature of the interview topics,
however, the Government was not able to fully debrief Minor Victim-4 over video. Due to travel
constraints and safety concerns arising from the COVID-19 pandemic, the Government was unable
to travel to meet with Minor Victim-4 until late January 2021, at which time the Government
conducted multiple in-person interviews with Minor Victim-4. The Government then took
additional investigative steps and sought the S2 Indictment in late March 2021, approximately two
months after concluding its debriefing of Minor Victim-4.
Simply put, the S2 Indictment was brought in a timely manner upon the Government’s
collection of evidence to support the additional charges. Any suggestion that the Government
intentionally delayed obtaining the S2 Indictment to gain some strategic advantage has no basis in
fact. The defendant has not established—and cannot establish—an undue delay, much less an
intentional and deliberate delay caused by the Government for an improper purpose.
collection of evidence to support the additional charges. Any suggestion that the Government
intentionally delayed obtaining the S2 Indictment to gain some strategic advantage has no basis in
fact. The defendant has not established—and cannot establish—an undue delay, much less an
intentional and deliberate delay caused by the Government for an improper purpose.
Finally, the defendant again asks the Court to “defer consideration of this motion until
trial.” (Def. Mot. at 22). The Court should again reject the defendant’s invitation to defer ruling
on this motion. See Apr. Op. at 18 (denying motion but allowing renewal of motion if the “factual
record at trial shows otherwise”); see also United States v. Muric, No. 10 Cr. 112 (LTS), 2010 WL
2891178, at *1 (S.D.N.Y. July 13, 2010) (“The motion to dismiss the Indictment as the result of
pre-indictment delay is therefore denied, without prejudice to appropriately supported later motion
trial.” (Def. Mot. at 22). The Court should again reject the defendant’s invitation to defer ruling
on this motion. See Apr. Op. at 18 (denying motion but allowing renewal of motion if the “factual
record at trial shows otherwise”); see also United States v. Muric, No. 10 Cr. 112 (LTS), 2010 WL
2891178, at *1 (S.D.N.Y. July 13, 2010) (“The motion to dismiss the Indictment as the result of
pre-indictment delay is therefore denied, without prejudice to appropriately supported later motion
15
DOJ-OGR-00004726
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