DOJ-OGR-00003129.jpg
764 KB
Extraction Summary
9
People
2
Organizations
0
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing / court document (case 1:20-cr-00330-pae)
File Size:
764 KB
Summary
This document is page 195 of 239 from a legal filing (Document 204) in the case United States v. Ghislaine Maxwell (1:20-cr-00330), filed on April 16, 2021. The text argues for the admissibility of evidence regarding 'Minor Victim-3' under Federal Rules of Evidence 403 and 404(b), stating that the defendant's grooming patterns were idiosyncratic and that the evidence is not unfairly prejudicial compared to the charges involving Victims 1 and 2. It explicitly states the defendant witnessed and participated in the abuse of victims at the hands of Epstein.
People (9)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant |
Ghislaine Maxwell (implied by case number); accused of preparing minor girls for sex acts with Epstein.
|
| Jeffrey Epstein | Associate of Defendant |
Mentioned as the person the defendant prepared minor girls for; committed abuse.
|
| Minor Victim-1 | Victim |
Victim whose experiences are compared to Minor Victim-3.
|
| Minor Victim-2 | Victim |
Victim whose experiences are compared to Minor Victim-3.
|
| Minor Victim-3 | Victim |
Subject of 'other acts evidence'; experienced similar abuse and grooming.
|
| Sliker | Case Citation Subject |
Referenced in case law States v. Sliker.
|
| Figueroa | Case Citation Subject |
Referenced in case law United States v. Figueroa.
|
| Rolan-Zapata | Case Citation Subject |
Referenced in case law United States v. Rolan-Zapata.
|
| Vickers | Case Citation Subject |
Referenced in case law United States v. Vickers regarding grooming evidence.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Department of Justice (DOJ) |
Indicated by Bates stamp 'DOJ-OGR'.
|
|
| Second Circuit Court of Appeals (2d Cir.) |
referenced in legal citations
|
Timeline (1 events)
Unspecified
Relationships (2)
Defendant prepared minor girls for sex acts with Epstein; witnessed and participated in abuse.
Defendant groomed/prepared Victim-3 for Epstein.
Key Quotes (3)
"Here, the defendant’s specific and unique approach to preparing minor girls to engage in sex acts with Epstein demonstrate the existence of such an idiosyncratic pattern warranting admission."Source
DOJ-OGR-00003129.jpg
Quote #1
"Those experiences include a wide range of abuse at the hands of Epstein, including abuse that the defendant witnessed and participated in herself."Source
DOJ-OGR-00003129.jpg
Quote #2
"Evidence regarding similar events involving Minor Victim-3, who was of a similar age and experienced similar types of sexual contact, is no more “sensational or disturbing” than the other acts detailed in the Indictment."Source
DOJ-OGR-00003129.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,253 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 195 of 239
States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984). Here, the defendant’s specific and unique
approach to preparing minor girls to engage in sex acts with Epstein demonstrate the existence of
such an idiosyncratic pattern warranting admission.
approach to preparing minor girls to engage in sex acts with Epstein demonstrate the existence of
such an idiosyncratic pattern warranting admission.
Other acts evidence is, like all other evidence, inadmissible under Rule 403 if its probative
value is substantially outweighed by the danger of unfair prejudice. See Fed. R. Evid. 403.
Evidence is unfairly prejudicial, however, “only when it tends to have some adverse effect upon a
defendant beyond tending to prove the fact or issue that justified its admission into evidence.”
United States v. Figueroa, 618 F.2d 934, 943 (2d Cir. 1980). Other acts evidence is typically not
unfairly prejudicial where it is not “any more sensational or disturbing than the crimes” with which
the defendant has been charged. United States v. Rolan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990).
Here, as already discussed, evidence regarding Minor Victim-3’s experiences with the defendant
and Epstein are no more inflammatory or upsetting than those of Minor Victim-1 and Minor
Victim-2. Those experiences include a wide range of abuse at the hands of Epstein, including
abuse that the defendant witnessed and participated in herself. Evidence regarding similar events
involving Minor Victim-3, who was of a similar age and experienced similar types of sexual
contact, is no more “sensational or disturbing” than the other acts detailed in the Indictment. Id.
Evidence of other acts involving the grooming or abuse of minor victims is regularly admitted for
similar purposes in cases where charges allege sexual activity with minors. See, e.g., United States
v. Vickers, 708 F. App’x 732, 737 (2d Cir. 2017) (“As to the testimony concerning Vickers’
‘grooming’ of his victims, we conclude that such evidence was admissible even under Rule 404(b),
because it was probative of Vickers’ knowledge of how to secure adolescent boys’ trust so that he
could sexually abuse them. We identify no abuse of discretion in the district court’s decision to
admit all of the challenged testimony [regarding uncharged acts of sexual abuse] under Rule
value is substantially outweighed by the danger of unfair prejudice. See Fed. R. Evid. 403.
Evidence is unfairly prejudicial, however, “only when it tends to have some adverse effect upon a
defendant beyond tending to prove the fact or issue that justified its admission into evidence.”
United States v. Figueroa, 618 F.2d 934, 943 (2d Cir. 1980). Other acts evidence is typically not
unfairly prejudicial where it is not “any more sensational or disturbing than the crimes” with which
the defendant has been charged. United States v. Rolan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990).
Here, as already discussed, evidence regarding Minor Victim-3’s experiences with the defendant
and Epstein are no more inflammatory or upsetting than those of Minor Victim-1 and Minor
Victim-2. Those experiences include a wide range of abuse at the hands of Epstein, including
abuse that the defendant witnessed and participated in herself. Evidence regarding similar events
involving Minor Victim-3, who was of a similar age and experienced similar types of sexual
contact, is no more “sensational or disturbing” than the other acts detailed in the Indictment. Id.
Evidence of other acts involving the grooming or abuse of minor victims is regularly admitted for
similar purposes in cases where charges allege sexual activity with minors. See, e.g., United States
v. Vickers, 708 F. App’x 732, 737 (2d Cir. 2017) (“As to the testimony concerning Vickers’
‘grooming’ of his victims, we conclude that such evidence was admissible even under Rule 404(b),
because it was probative of Vickers’ knowledge of how to secure adolescent boys’ trust so that he
could sexually abuse them. We identify no abuse of discretion in the district court’s decision to
admit all of the challenged testimony [regarding uncharged acts of sexual abuse] under Rule
168
DOJ-OGR-00003129
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