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682 KB
Extraction Summary
3
People
3
Organizations
2
Locations
4
Events
1
Relationships
4
Quotes
Document Information
Type:
Court filing / legal memorandum
File Size:
682 KB
Summary
This legal filing argues for the admissibility of evidence regarding the USAO-SDFL's 2008 decision not to charge Ghislaine Maxwell. It highlights inconsistencies in a redacted witness's testimony between 2007 and 2020, specifically noting that the witness only accused Maxwell of sexual contact (fondling breasts) 13 years later during an interview with the New York FBI. The document lists various evidentiary exhibits including message pad slips, phone records, and FedEx records.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Accused of seeing a witness naked and fondling her breasts; subject of charging decisions in 2008 and 2020.
|
| [Redacted] | Witness/Accuser |
Provided testimony claiming Maxwell fondled her; changed story 13 years later; credibility is being challenged.
|
| [Redacted] | Special Agent |
Had first-hand knowledge that Maxwell was not charged in SDFL; presented indictment to the grand jury.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| USAO-SDFL |
United States Attorney's Office for the Southern District of Florida; decided not to charge Maxwell in 2008.
|
|
| New York FBI |
Interviewed the redacted witness 13 years after the initial events.
|
|
| DOJ |
Department of Justice (indicated by Bates stamp DOJ-OGR).
|
Timeline (4 events)
2007
2008
USAO-SDFL decision not to charge Ms. Maxwell.
Southern District of Florida
2020
Locations (2)
| Location | Context |
|---|---|
|
Location of proposed indictment and 2008 decision not to charge.
|
|
|
Location of FBI interview and subsequent investigation.
|
Relationships (1)
Witness claims Maxwell saw her naked and fondled her breasts.
Key Quotes (4)
"[Redacted] went even further, claiming that Ms. Maxwell saw her naked several times and even fondled [Redacted] breasts on one occasion."Source
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Quote #1
"The decision by the USAO-SDFL not to charge Ms. Maxwell in 2008 is therefore relevant and admissible."Source
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Quote #2
"The only difference is that [Redacted] changed her story and accused Ms. Maxwell thirteen years later when she was interviewed by the New York FBI."Source
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Quote #3
"The viability of Counts Five and Six of the S2 Indictment rise and fall on the credibility of [Redacted]."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,007 characters)
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 47 of 69
interviews, [REDACTED] went even further, claiming that Ms. Maxwell saw her naked several
times and even fondled [REDACTED] breasts on one occasion. See 3505-074 at 3.
times and even fondled [REDACTED] breasts on one occasion. See 3505-074 at 3.
Count Two of the proposed SDFL indictment is the same as Count Six of the S2
Indictment and it is based on the exact same evidence that the government proposes to introduce
to support Count Six; namely, the testimony of [REDACTED] and related documentary evidence.
See GX-1-A through GX-1-P; GX-2-A through GX-2-W; GX-3-A through GX-3-KK; GX-4-A
through GX-4-K (message pad slips); GX-551 ([REDACTED] phone records); GX-801-803
(FedEx records). The only difference is that [REDACTED] changed her story and accused Ms.
Maxwell thirteen years later when she was interviewed by the New York FBI. The fact that [REDACTED]
[REDACTED] testimony led to two different charging decisions on two different occasions is
relevant to her credibility and the government’s acceptance of her differing testimony. The
decision by the USAO-SDFL not to charge Ms. Maxwell in 2008 is therefore relevant and
admissible. See Borrero, 2013 WL 6020773, at *2.
Indictment and it is based on the exact same evidence that the government proposes to introduce
to support Count Six; namely, the testimony of [REDACTED] and related documentary evidence.
See GX-1-A through GX-1-P; GX-2-A through GX-2-W; GX-3-A through GX-3-KK; GX-4-A
through GX-4-K (message pad slips); GX-551 ([REDACTED] phone records); GX-801-803
(FedEx records). The only difference is that [REDACTED] changed her story and accused Ms.
Maxwell thirteen years later when she was interviewed by the New York FBI. The fact that [REDACTED]
[REDACTED] testimony led to two different charging decisions on two different occasions is
relevant to her credibility and the government’s acceptance of her differing testimony. The
decision by the USAO-SDFL not to charge Ms. Maxwell in 2008 is therefore relevant and
admissible. See Borrero, 2013 WL 6020773, at *2.
This evidence could be elicited without hearsay. Special Agent [REDACTED] had first-
hand knowledge that Ms. Maxwell was not charged in the proposed SDFL indictment becauseshe presented the indictment to the grand jury. See 3505-018 at 28:5-8. And it should not be
excluded under Rule 403. The viability of Counts Five and Six of the S2 Indictment rise and fall
on the credibility of [REDACTED]. Moreover, the government’s decision to credit [REDACTED]
[REDACTED] 2020 testimony, despite its obvious inconsistencies with her 2007 testimony, goes to
the thoroughness and good faith of the New York investigation. The fact that Ms. Maxwell was
not charged in 2008 is highly probative of both issues and is not substantially outweighed by the
risk of juror confusion or speculation. It is therefore admissible.
hand knowledge that Ms. Maxwell was not charged in the proposed SDFL indictment becauseshe presented the indictment to the grand jury. See 3505-018 at 28:5-8. And it should not be
excluded under Rule 403. The viability of Counts Five and Six of the S2 Indictment rise and fall
on the credibility of [REDACTED]. Moreover, the government’s decision to credit [REDACTED]
[REDACTED] 2020 testimony, despite its obvious inconsistencies with her 2007 testimony, goes to
the thoroughness and good faith of the New York investigation. The fact that Ms. Maxwell was
not charged in 2008 is highly probative of both issues and is not substantially outweighed by the
risk of juror confusion or speculation. It is therefore admissible.
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DOJ-OGR-00005502
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