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593 KB
Extraction Summary
5
People
2
Organizations
1
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal filing / court motion (defense reply regarding bail/evidence)
File Size:
593 KB
Summary
This page from a defense filing (Case 1:20-cr-00330-AJN) argues that the government's case against Ghislaine Maxwell relies entirely on the uncorroborated testimony of three accusers, specifically noting that Counts Two and Four rely solely on 'Minor Victim-1'. The defense asserts that the government only began issuing subpoenas regarding Maxwell after Jeffrey Epstein's death, suggesting the case was assembled 'after the fact'. A large block of text regarding specific government evidence is redacted.
People (5)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Subject of the legal defense arguments; accused of grooming and facilitating abuse.
|
| Jeffrey Epstein | Deceased Associate |
Mentioned regarding the timing of subpoenas relative to his death.
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| Minor Victim-1 | Witness/Accuser |
Sole witness for substantive Counts Two and Four.
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| Three accusers | Witnesses |
The primary source of testimony against Maxwell.
|
| Additional witnesses | Witnesses |
Mentioned in footnote 1; government claims they will testify Maxwell interacted with minors.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
Referenced as the opposing party assembling the case.
|
|
| The Court |
Recipient of the filing and a letter from a witness.
|
Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
Cited in case law (United States v. Turner) in footnote 2.
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Relationships (2)
Text discusses Maxwell facilitating Epstein's abuse; mentions they interacted with victims together.
Counts Two and Four are based on testimony of Minor Victim-1.
Key Quotes (5)
"The only purported corroboration that pertains in any way to Ms. Maxwell is of marginal value."Source
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Quote #1
"It is clear that the only evidence that Ms. Maxwell allegedly “groomed” the accusers or knowingly facilitated or participated in Epstein’s sexual abuse of minors will come solely from the testimony of the three accusers."Source
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Quote #2
"The government’s case against Ms. Maxwell therefore rests entirely on the credibility and reliability of these three witnesses."Source
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Quote #3
"It is also telling that the government does not even attempt to rebut the defense’s assertion that it did not begin issuing subpoenas for documents related to Ms. Maxwell until just after the death of Jeffrey Epstein."Source
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Quote #4
"This confirms that the case against Ms. Maxwell was assembled after the fact"Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,102 characters)
Case 1:20-cr-00330-AJN Document 103-2 Filed 08/23/20 Page 7 of 15
here. Whether or not the accusers’ recollections as to Epstein are corroborated is irrelevant to the strength of the evidence against Ms. Maxwell.
The only purported corroboration that pertains in any way to Ms. Maxwell is of marginal value. The government references [REDACTED]
(Id. at 11). But even the government concedes that, at best, [REDACTED]
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(Id. at 11). But even the government concedes that, at best, [REDACTED]
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1
It is clear that the only evidence that Ms. Maxwell allegedly “groomed” the accusers or knowingly facilitated or participated in Epstein’s sexual abuse of minors will come solely from the testimony of the three accusers. The government’s case against Ms. Maxwell therefore rests entirely on the credibility and reliability of these three witnesses.² Moreover, the substantive counts (Counts Two and Four) are based on the testimony of only one witness, Minor Victim-1.
It is also telling that the government does not even attempt to rebut the defense’s assertion that it did not begin issuing subpoenas for documents related to Ms. Maxwell until just after the death of Jeffrey Epstein. This confirms that the case against Ms. Maxwell was assembled after the fact
It is also telling that the government does not even attempt to rebut the defense’s assertion that it did not begin issuing subpoenas for documents related to Ms. Maxwell until just after the death of Jeffrey Epstein. This confirms that the case against Ms. Maxwell was assembled after the fact
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¹ The government also proffers that they will have “additional witnesses.” (Gov. Mem. at 11). But these are not “outcry” witnesses who will corroborate a contemporaneous account of abuse from one or more of the accusers. Instead, they will testify only that “both [Ms. Maxwell] and Epstein knew and interacted with certain minor victims when those victims were minors.” (Id.). Again, the fact that Ms. Maxwell may have “met and interacted with” someone when they were a minor proves absolutely nothing.
² One of the witnesses has submitted a letter to the Court. While the CVRA permits the right to be heard, the letter should be given no legal weight in the Court’s bail analysis. See United States v. Turner, 367 F. Supp. 2d 319, 331-32 (E.D.N.Y. 2005)
¹ The government also proffers that they will have “additional witnesses.” (Gov. Mem. at 11). But these are not “outcry” witnesses who will corroborate a contemporaneous account of abuse from one or more of the accusers. Instead, they will testify only that “both [Ms. Maxwell] and Epstein knew and interacted with certain minor victims when those victims were minors.” (Id.). Again, the fact that Ms. Maxwell may have “met and interacted with” someone when they were a minor proves absolutely nothing.
² One of the witnesses has submitted a letter to the Court. While the CVRA permits the right to be heard, the letter should be given no legal weight in the Court’s bail analysis. See United States v. Turner, 367 F. Supp. 2d 319, 331-32 (E.D.N.Y. 2005)
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