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686 KB
Extraction Summary
4
People
3
Organizations
1
Locations
1
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal filing / court document (government response to defense motion)
File Size:
686 KB
Summary
This document is a page from a Government legal filing (dated Oct 29, 2021) in the case against Ghislaine Maxwell. The Government rebuts defense accusations regarding discovery violations, stating they provided co-conspirator statements 'unusually early' (seven weeks before trial). Additionally, the Government argues against suppressing the identification of the defendant by 'Minor Victim-4,' asserting that the victim knew the defendant personally for decades.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Referred to as 'The defendant'; subject of Minor Victim-4's identification.
|
| Minor Victim-4 | Victim/Witness |
Identified the defendant personally; described defendant for decades.
|
| The Government | Prosecution |
Defending against accusations of discovery violations.
|
| The Defense | Legal Counsel |
Accusing government of violating orders; moving to suppress identification.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Supreme Court |
Referenced for legal precedent (Taylor case).
|
|
| The Court |
Southern District of New York (implied); adjudicating the current motion.
|
|
| Department of Justice (DOJ) |
Source of document (Footer: DOJ-OGR).
|
Timeline (1 events)
Locations (1)
| Location | Context |
|---|---|
|
Likely Southern District of New York (based on case number context), referring to local legal practices.
|
Relationships (1)
Minor Victim-4 knew the defendant personally, and she has consistently described the defendant for decades.
Key Quotes (5)
"The Supreme Court found the discovery violation was “both willful and blatant.”"Source
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Quote #1
"The defense’s accusations are baseless and offensive."Source
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Quote #2
"accusing the Government of “attempting to overstuff an already full sandbag”"Source
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Quote #3
"The Government has simply read the word “disclose” to mean “disclose,” consistent with the uniform practice in this District."Source
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Quote #4
"Minor Victim-4 knew the defendant personally, and she has consistently described the defendant for decades."Source
DOJ-OGR-00005847.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,001 characters)
Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 64 of 84
excluding the testimony of a defense witness as a sanction for counsel’s (i) noncompliance with a
discovery rule that required notice of intention to call the witness, and (ii) misleading the court
concerning his knowledge of the witness’s whereabouts. The Supreme Court found the discovery
violation was “both willful and blatant.” Id. at 416. Taylor does not support the defense’s position.
The defense, citing Taylor, accuses the Government of willfully violating the Court’s September
3, 2021 Order. (See Def. Mot. 1 at 6-7; see id. at 3 (accusing the Government of “attempting to
overstuff an already full sandbag”)). The Government did no such thing. The Government has
simply read the word “disclose” to mean “disclose,” consistent with the uniform practice in this
District. The defense’s accusations are baseless and offensive.
discovery rule that required notice of intention to call the witness, and (ii) misleading the court
concerning his knowledge of the witness’s whereabouts. The Supreme Court found the discovery
violation was “both willful and blatant.” Id. at 416. Taylor does not support the defense’s position.
The defense, citing Taylor, accuses the Government of willfully violating the Court’s September
3, 2021 Order. (See Def. Mot. 1 at 6-7; see id. at 3 (accusing the Government of “attempting to
overstuff an already full sandbag”)). The Government did no such thing. The Government has
simply read the word “disclose” to mean “disclose,” consistent with the uniform practice in this
District. The defense’s accusations are baseless and offensive.
The defense has all of the co-conspirator statements the Government plans to use at trial.
They have these records “unusually early”—seven weeks before trial. (Endorsed Letter at 3, Dkt.
No. 353). The defense also knows the identities of the limited number of co-conspirators to whom
the Government may refer at trial, a highly unusual circumstance that makes the defense’s task
even easier. And they are free to litigate the admissibility of any such statement during trial. The
Government has complied with its obligations, and the defense is fully equipped to prepare for
trial. The Court should deny the motion.
They have these records “unusually early”—seven weeks before trial. (Endorsed Letter at 3, Dkt.
No. 353). The defense also knows the identities of the limited number of co-conspirators to whom
the Government may refer at trial, a highly unusual circumstance that makes the defense’s task
even easier. And they are free to litigate the admissibility of any such statement during trial. The
Government has complied with its obligations, and the defense is fully equipped to prepare for
trial. The Court should deny the motion.
V. There is No Basis to Suppress Minor Victim-4’s Identification of the Defendant
The defendant claims that Minor Victim-4’s identification of her was unduly suggestive
and should be suppressed. (Def. Mot. 9). That argument finds support in neither fact nor law.
Minor Victim-4 knew the defendant personally, and she has consistently described the defendant
for decades. The identification was not suggestive, and the motion should be denied.
and should be suppressed. (Def. Mot. 9). That argument finds support in neither fact nor law.
Minor Victim-4 knew the defendant personally, and she has consistently described the defendant
for decades. The identification was not suggestive, and the motion should be denied.
A. Background
63
DOJ-OGR-00005847
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