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546 KB

Extraction Summary

4
People
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Organizations
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Locations
2
Events
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Relationships
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Quotes

Document Information

Type: Legal filing (defense response/motion in limine)
File Size: 546 KB
Summary

This document is page 64 of a legal filing (Document 382) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on October 29, 2021. The defense argues against government motions to exclude evidence regarding Maxwell's 'charitable works' and 'family history,' suggesting these may become relevant if the government opens those topics. Section X argues strongly against the government's request to preview the defense's evidence, using the metaphor of having 'hands tied behind their back and their mouths duct-taped,' while noting that accusers are testifying under anonymity.

People (4)

Name Role Context
Ms. Maxwell Defendant
Subject of the trial; defense argues against government restrictions on her evidence regarding charitable works and f...
Defense Counsel Legal Representation
Lawyers representing Ms. Maxwell; described metaphorically as having 'hands tied' and 'mouths duct-taped' by governme...
The Government Prosecution
Attempting to limit defense evidence and preview defense strategy.
The Court Judiciary
Judge presiding over the case; being asked to deny government requests.

Organizations (2)

Name Type Context
DOJ
Department of Justice (implied by DOJ-OGR stamp)
The Court
The judicial body hearing the case (Southern District of New York per case number format)

Timeline (2 events)

2021-10-29
Filing of Document 382 in Case 1:20-cr-00330-PAE
Court
TBD (Future context)
Trial
Court
Ms. Maxwell Witnesses Accusers

Relationships (1)

Ms. Maxwell Adversarial (Legal) The Government
Government seeking to limit Maxwell's defense evidence; Maxwell's team accusing government of trying to 'tie their hands'.

Key Quotes (3)

"The government would like nothing better than for the Court to require defense counsel to have their hands tied behind their back and their mouths duct-taped while the accusers, and related witnesses, testify under anonymity"
Source
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Quote #1
"If the government wants to preclude the interposing of defenses, it should dismiss the case."
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Quote #2
"One wonders if the government is suggesting these topics because it intends to try to elicit some testimony on these topics and then preclude Ms. Maxwell from responding."
Source
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Quote #3

Full Extracted Text

Complete text extracted from the document (1,822 characters)

Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 64 of 69
examples were given, the Court finds that this is too vague a category to grant the relief
requested.").
The government has not explained why they believe that counsel does not understand
these rules or what evidence (beyond "charitable works" or "evidence of her family history") that
they expect to be offered at trial. If the topic of "charitable works" comes up in the government's
case, then topics of Ms. Maxwell's "charitable works" may become relevant. If the topic of Ms.
Maxwell's family history is elicited or argued by the government, then topics of Ms. Maxwell's
family history may become relevant. One wonders if the government is suggesting these topics
because it intends to try to elicit some testimony on these topics and then preclude Ms. Maxwell
from responding. If that were the case, then the government should have said so in their Motion.
Regardless, there is no reason for the Court to enter any orders on this topic. Ms. Maxwell will
tender evidence on cross examination and in her defense case that is relevant. The government is
free to make any objections it deems appropriate at that time, with reference to any evidence the
government has already elicited from the witnesses and in opening statements.
X. REQUEST TO PREVIEW DEFENSE'S EVIDENCE SHOULD BE DENIED
The government would like nothing better than for the Court to require defense counsel
to have their hands tied behind their back and their mouths duct-taped while the accusers, and
related witnesses, testify under anonymity, [REDACTED]. If the government wants to preclude the interposing of
defenses, it should dismiss the case.
The government is not and should not be privy to the defenses Ms. Maxwell may
interpose at trial, [REDACTED]
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