DOJ-OGR-00013210.jpg
635 KB
Extraction Summary
6
People
4
Organizations
0
Locations
2
Events
4
Relationships
4
Quotes
Document Information
Type:
Court transcript
File Size:
635 KB
Summary
This document is a page from a court transcript (United States v. Ghislaine Maxwell) dated August 10, 2022. Defense attorney Mr. Pagliuca is arguing to admit a prior document for 'impeachment by omission,' stating that the witness (Carolyn) filed a complaint and was interviewed by the FBI in 2008 regarding sexual abuse by Epstein and his employee Sarah Kellen, but notably failed to mention Ghislaine Maxwell at that time. Pagliuca argues this contradicts the government's current narrative which emphasizes Maxwell's role while downplaying Kellen's.
People (6)
| Name | Role | Context |
|---|---|---|
| Jeffrey Pagliuca | Defense Attorney |
Identified as 'MR. PAGLIUCA', speaking to the judge regarding impeachment by omission.
|
| Carolyn | Witness |
Mentioned in the header ('Carolyn - cross') and referred to as 'the witness' who claims sexual abuse.
|
| Jeffrey Epstein | Accused |
Mentioned as the subject of a previous complaint filed by the witness.
|
| Sarah Kellen | Epstein Employee |
Described as an employee highlighted in the witness's complaint; Pagliuca argues her role was downplayed by the gover...
|
| Ghislaine Maxwell | Defendant |
Pagliuca argues she was omitted from the witness's 2008 complaint but her role is now being 'up-played' by the govern...
|
| The Judge | Judge |
Addressed as 'your Honor'.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| FBI |
Mentioned regarding an interview with the witness in 2008.
|
|
| Southern District Reporters, P.C. |
Court reporting agency listed in the footer.
|
|
| First Circuit |
Referenced as a legal jurisdiction supporting the theory of impeachment by omission.
|
|
| DOJ |
Department of Justice (inferred from footer DOJ-OGR).
|
Relationships (4)
Witness claims sexually abused her; filed complaint against him.
Described as 'one of Epstein's employees'.
Complaint highlighted Sarah Kellen.
Defense argues Carolyn omitted Maxwell from previous complaints.
Key Quotes (4)
"The entire testimony by the government here through this witness has downplayed the role of Sarah Kellen and up-played the role of Ghislaine Maxwell"Source
DOJ-OGR-00013210.jpg
Quote #1
"in 2008, shortly after being interviewed by the FBI about the same subject matter with counsel, there is no mention of Maxwell in this entire complaint."Source
DOJ-OGR-00013210.jpg
Quote #2
"This is a complaint against two people that this witness claims sexually abused her. It's not only against Epstein, it's against one of Epstein's employees who is highlighted in this complaint."Source
DOJ-OGR-00013210.jpg
Quote #3
"impeachment by omission typically occurs where there is a document or a statement where the witness would likely include whatever is omitted"Source
DOJ-OGR-00013210.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,637 characters)
Case 1:20-cr-00330-PAE Document 753 Filed 08/10/22 Page 197 of 264 1638
LC7Cmax6 Carolyn - cross
LC7Cmax6 Carolyn - cross
1 factual inconsistency.
2 MR. PAGLIUCA: Well, your Honor, there are two
3 principals at play here.
4 The first is this is what is commonly referred to as
5 impeachment by omission, which is a subset of impeachment by
6 contradiction. Impeachment by omission typically occurs where
7 there is a document or a statement where the witness would
8 likely include whatever is omitted, and this is such a
9 document, and I am seeking to impeach by omission through this
10 document. This is a complaint against two people that this
11 witness claims sexually abused her. It's not only against
12 Epstein, it's against one of Epstein's employees who is
13 highlighted in this complaint. The entire testimony by the
14 government here through this witness has downplayed the role of
15 Sarah Kellen and up-played the role of Ghislaine Maxwell, and
16 it is an impeachment by omission that, in 2008, shortly after
17 being interviewed by the FBI about the same subject matter with
18 counsel, there is no mention of Maxwell in this entire
19 complaint. I think that is significant under the facts of this
20 case. So, I think it is admissible under that theory and there
21 is ample federal law, First Circuit, this circuit, that
22 supports that theory of impeachment by omission. And these
23 factual paragraphs, I believe, are also impeaching of the
24 witness's testimony because it is inconsistent with the things
25 that she has claimed happened to her in addition to these
2 MR. PAGLIUCA: Well, your Honor, there are two
3 principals at play here.
4 The first is this is what is commonly referred to as
5 impeachment by omission, which is a subset of impeachment by
6 contradiction. Impeachment by omission typically occurs where
7 there is a document or a statement where the witness would
8 likely include whatever is omitted, and this is such a
9 document, and I am seeking to impeach by omission through this
10 document. This is a complaint against two people that this
11 witness claims sexually abused her. It's not only against
12 Epstein, it's against one of Epstein's employees who is
13 highlighted in this complaint. The entire testimony by the
14 government here through this witness has downplayed the role of
15 Sarah Kellen and up-played the role of Ghislaine Maxwell, and
16 it is an impeachment by omission that, in 2008, shortly after
17 being interviewed by the FBI about the same subject matter with
18 counsel, there is no mention of Maxwell in this entire
19 complaint. I think that is significant under the facts of this
20 case. So, I think it is admissible under that theory and there
21 is ample federal law, First Circuit, this circuit, that
22 supports that theory of impeachment by omission. And these
23 factual paragraphs, I believe, are also impeaching of the
24 witness's testimony because it is inconsistent with the things
25 that she has claimed happened to her in addition to these
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
(212) 805-0300
DOJ-OGR-00013210
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