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749 KB
Extraction Summary
4
People
2
Organizations
0
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal filing (motion to sever counts)
File Size:
749 KB
Summary
This document is an introduction to a legal motion filed by Ghislaine Maxwell's defense on January 25, 2021, requesting the severance of perjury charges (Counts Five and Six) from sex trafficking charges (Counts One through Four). The defense argues that joining these counts causes substantial prejudice because the perjury charges stem from a 2016 civil defamation suit involving Virginia Roberts Giuffre, whose allegations the defense characterizes as false and financially motivated. The document contends that Giuffre is not one of the accusers in the primary trafficking counts and that introducing her testimony would improperly influence the jury regarding conduct alleged to have occurred between 1994 and 1997.
People (4)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Requesting severance of counts in the indictment; argues prejudice.
|
| Virginia Roberts Giuffre | Plaintiff (Civil Action) |
Plaintiff in the 2016 defamation action; accused Maxwell and Epstein of trafficking.
|
| Jeffrey Epstein | Alleged Co-conspirator |
Mentioned as the person who allegedly trafficked Giuffre alongside Maxwell.
|
| Professor Alan Dershowitz | Accused Party (Civil Context) |
Accused by Giuffre; denounced her as a 'serial liar'.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Court |
The entity requested to enter the order severing counts.
|
|
| The Government |
Opposing party in the criminal case.
|
Timeline (2 events)
1994-1997
Relationships (3)
Giuffre sued Maxwell for defamation; Maxwell denies Giuffre's allegations.
Giuffre accused Dershowitz; Dershowitz called her a 'serial liar'.
Accused together of trafficking by Giuffre.
Key Quotes (4)
"Giuffre’s stories, sold to tabloids for large sums of money, were in fact false."Source
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Quote #1
"Professor Alan Dershowitz, for example, denounced her as a 'serial liar.'"Source
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Quote #2
"Ms. Giuffre is not one of the three accusers identified in Counts One through Four"Source
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Quote #3
"wild and false accusations that she had been sexually trafficked by Epstein and Ms. Maxwell to dozens of famous politicians, professors, foreign leaders, and others."Source
DOJ-OGR-00002283(1).jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,176 characters)
Case 1:20-cr-00330-AJN Document 120 Filed 01/25/21 Page 5 of 19
INTRODUCTION
Ms. Maxwell, pursuant to Fed. R. Crim. P. 8(a) and 14, requests that the Court enter an
order severing Counts Five and Six of the Superseding Indictment (“Indictment”) from Counts
One through Four because these Counts have been improperly joined and a joint trial would
result in substantial prejudice to Ms. Maxwell.
order severing Counts Five and Six of the Superseding Indictment (“Indictment”) from Counts
One through Four because these Counts have been improperly joined and a joint trial would
result in substantial prejudice to Ms. Maxwell.
Counts Five and Six of the Indictment allege that Ms. Maxwell made materially false
statements at two civil depositions in 2016 that were part of a defamation action brought against
her more than twenty years after the conduct alleged in Counts One through Four supposedly
took place (1994-1997). The plaintiff in the defamation action, Virginia Roberts Giuffre, made
wild and false accusations that she had been sexually trafficked by Epstein and Ms. Maxwell to
dozens of famous politicians, professors, foreign leaders, and others. When Ms. Maxwell denied
these allegations as false, Giuffre sued for defamation. Discovery conducted in the defamation
action established that Giuffre’s stories, sold to tabloids for large sums of money, were in fact
false. Those accused by Ms. Giuffre, Professor Alan Dershowitz, for example, denounced her as
a “serial liar.” Regardless, Ms. Giuffre is not one of the three accusers identified in Counts One
through Four of the Superseding Indictment and her claims relate to a different time period
entirely. Allowing Counts Five and Six to be tried along with Counts One through Four will
significantly prejudice Ms. Maxwell because it will allow the government to introduce testimony
of alleged sexual abuse that purportedly occurred outside of the time period alleged in Counts
One through Four, despite the fact that Ms. Maxwell (unlike Jeffrey Epstein) was never
criminally charged with that conduct. As a result, the jury may convict Ms. Maxwell of Counts
One through Four based on an improper inference of criminal propensity.
statements at two civil depositions in 2016 that were part of a defamation action brought against
her more than twenty years after the conduct alleged in Counts One through Four supposedly
took place (1994-1997). The plaintiff in the defamation action, Virginia Roberts Giuffre, made
wild and false accusations that she had been sexually trafficked by Epstein and Ms. Maxwell to
dozens of famous politicians, professors, foreign leaders, and others. When Ms. Maxwell denied
these allegations as false, Giuffre sued for defamation. Discovery conducted in the defamation
action established that Giuffre’s stories, sold to tabloids for large sums of money, were in fact
false. Those accused by Ms. Giuffre, Professor Alan Dershowitz, for example, denounced her as
a “serial liar.” Regardless, Ms. Giuffre is not one of the three accusers identified in Counts One
through Four of the Superseding Indictment and her claims relate to a different time period
entirely. Allowing Counts Five and Six to be tried along with Counts One through Four will
significantly prejudice Ms. Maxwell because it will allow the government to introduce testimony
of alleged sexual abuse that purportedly occurred outside of the time period alleged in Counts
One through Four, despite the fact that Ms. Maxwell (unlike Jeffrey Epstein) was never
criminally charged with that conduct. As a result, the jury may convict Ms. Maxwell of Counts
One through Four based on an improper inference of criminal propensity.
Furthermore, the Court and the jury and the Court will have to resolve numerous complex
legal and factual issues in connection with the perjury charges that will lengthen and complicate
legal and factual issues in connection with the perjury charges that will lengthen and complicate
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DOJ-OGR-00002283
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