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612 KB

Extraction Summary

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

Document Information

Type: Legal filing / court brief (appellate)
File Size: 612 KB
Summary

This legal document page (dated April 1, 2021) argues that the government lacks any contemporaneous documentary evidence (emails, texts, police reports) to corroborate allegations against Ghislaine Maxwell regarding conduct between 1994 and 1997. The defense asserts that Maxwell is being prosecuted as a 'substitute' for Jeffrey Epstein following his 'inexplicable death' at the MCC, noting that she was not named in Epstein's original indictment.

People (3)

Name Role Context
Ms. Maxwell Defendant
Accused of conspiracy involving conduct from 1994-1997; described as being charged as a substitute for Epstein.
Jeffrey Epstein Main Target (Deceased)
Described as having an 'inexplicable death at MCC'; original indictment did not name Maxwell.
Accusers Witnesses/Victims
Unnamed individuals making allegations about events from 1994-97; names refused to be disclosed by government.

Organizations (5)

Name Type Context
The Government
Accused of failing to provide corroborating documentation and refusing to disclose accuser names.
Fifth Circuit
Cited for legal precedent regarding indictments.
Sixth Circuit
Cited for legal precedent regarding indictments.
MCC
Metropolitan Correctional Center, location of Epstein's death.
DOJ
Department of Justice (indicated by Bates stamp DOJ-OGR).

Timeline (2 events)

1994-1997
Alleged conduct underlying the conspiracy charged in the indictment.
Unspecified
Unspecified
Epstein's death
MCC

Locations (1)

Location Context
MCC
Location of Epstein's death.

Relationships (2)

Ms. Maxwell Legal/Co-conspirator context Jeffrey Epstein
Text states Maxwell was charged as a 'substitute for Epstein' but was not named in his original indictment.
The Government Legal Adversary Ms. Maxwell
Government bringing charges against Maxwell.

Key Quotes (5)

"The government did not provide one single document to the court to back up its claims that the accusers’ allegations about events from 1994-97 were truthful."
Source
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Quote #1
"“[T]he discovery contains not a single contemporaneous email, text message, phone record, diary entry, police report, or recording that implicates Ms. Maxwell in the 1994-1997 conduct underlying the conspiracy charged in the indictment.”"
Source
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Quote #2
"The government only made these allegations after Epstein’s inexplicable death at MCC."
Source
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Quote #3
"She was charged as a substitute for Epstein."
Source
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Quote #4
"Reverse engineering a charge many years later because of the main target’s death is not the makings of a strong case."
Source
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Quote #5

Full Extracted Text

Complete text extracted from the document (1,290 characters)

Case 21-770, Document 20-1, 04/01/2021, 3068530, Page22 of 31
in making your decision in this case.”); Fifth Circuit: (“The indictment
... is only an accusation, nothing more. It is not proof of guilt or
anything else. The defendant therefore starts out with a clean slate.”);
Sixth Circuit: (“The indictment ... does not even raise any suspicion of
guilt.”).
The government did not provide one single document to the court
to back up its claims that the accusers’ allegations about events from
1994-97 were truthful. The government has refused to disclose even the
names of these accusers. Contrary to its assertions to the lower court,
its allegations are not corroborated. Ex.E at 30-33 (“[T]he discovery
contains not a single contemporaneous email, text message, phone
record, diary entry, police report, or recording that implicates Ms.
Maxwell in the 1994-1997 conduct underlying the conspiracy charged in
the indictment.”).
The government only made these allegations after Epstein’s
inexplicable death at MCC. Ms. Maxwell was not named in Epstein’s
indictment as a defendant or a co-conspirator. She was charged as a
substitute for Epstein. Reverse engineering a charge many years later
because of the main target’s death is not the makings of a strong case.
20
DOJ-OGR-00000932

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