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544 KB

Extraction Summary

5
People
0
Organizations
0
Locations
2
Events
4
Relationships
11
Quotes

Document Information

Type: Legal document
File Size: 544 KB
Summary

This legal document, part of a filing on behalf of Ms. Maxwell, argues that the indictment against her is unconstitutionally vague. It claims the inconsistent use of terms like "minor victims" and "girls," combined with a lack of specific dates for alleged crimes from decades ago, prevents Maxwell from preparing an adequate defense. The filing asserts this vagueness makes it impossible to investigate the allegations or challenge the prosecution's evidence effectively at trial.

People (5)

Name Role Context
Epstein
Mentioned in the phrase "Epstein's minor victims".
Minor Victim-1 Alleged Victim
Identified as one of the minor victims in the indictment.
Minor Victim-2 Alleged Victim
Identified as one of the minor victims in the indictment and mentioned in the context of being taken to a movie.
Minor Victim-3 Alleged Victim
Identified as one of the minor victims in the indictment.
Ms. Maxwell Defendant
The subject of the legal filing, arguing that the indictment is too vague for her to prepare a defense.

Timeline (2 events)

Alleged instances of sexual abuse took place over a three-year period beginning approximately 27 years in the past.
Ms. Maxwell allegedly "took Minor Victim -2 to a movie".

Relationships (4)

Ms. Maxwell Alleged perpetrator-victim Minor Victim-1
The document states that the indictment alleges Ms. Maxwell engaged in certain acts with respect to minor victims, including Minor Victim-1.
Ms. Maxwell Alleged perpetrator-victim Minor Victim-2
The document states that the indictment alleges Ms. Maxwell engaged in certain acts with respect to minor victims, including taking Minor Victim-2 to a movie.
Ms. Maxwell Alleged perpetrator-victim Minor Victim-3
The document states that the indictment alleges Ms. Maxwell engaged in certain acts with respect to minor victims, including Minor Victim-3.
Epstein Alleged perpetrator-victim minor victims
The document quotes the phrase "Epstein's minor victims" from the indictment.

Key Quotes (11)

"some of the minor girls"
Source
— Indictment (Quoted from the indictment to show vague terminology for victims.)
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Quote #1
"multiple minor girls"
Source
— Indictment (Quoted from the indictment to show vague terminology for victims.)
DOJ-OGR-00002316(1).jpg
Quote #2
"Epstein's minor victims"
Source
— Indictment (Quoted from the indictment.)
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Quote #3
"a minor victim"
Source
— Indictment (Quoted from the indictment to show vague terminology for victims.)
DOJ-OGR-00002316(1).jpg
Quote #4
"Among the victims ... were minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3."
Source
— Indictment (Quoted from the indictment identifying specific alleged victims.)
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Quote #5
"engaged in the following acts, among others, with respect to minor victims...."
Source
— Indictment (Quoted from the indictment.)
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Quote #6
"befriend"
Source
— Indictment (Quoted as a random act disbursed throughout the indictment.)
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Quote #7
"being present"
Source
— Indictment (Quoted as a random act disbursed throughout the indictment.)
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Quote #8
"groomed"
Source
— Indictment (Quoted as a random act disbursed throughout the indictment.)
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Quote #9
"undressing"
Source
— Indictment (Quoted as a random act disbursed throughout the indictment.)
DOJ-OGR-00002316(1).jpg
Quote #10
"took Minor Victim -2 to a movie"
Source
— Indictment (Quoted as a random act disbursed throughout the indictment, tied to a specific alleged victim.)
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Quote #11

Full Extracted Text

Complete text extracted from the document (1,482 characters)

Case 1:20-cr-00330-AJN Document 124 Filed 01/25/21 Page 6 of 8
* "some of the minor girls" ¶ 2;
* "multiple minor girls" ¶ 4;
* "Epstein's minor victims" ¶ 4a;
* "a minor victim" ¶ 4b;
* "Among the victims ... were minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3." ¶ 7; and
* "engaged in the following acts, among others, with respect to minor victims...." ¶ 7.
The inconsistent and interchangeable use of seemingly defined alleged victims, i.e., Minor Victim-1, with generic undefined "victims," "minor victims", and "girls," prevents Ms. Maxwell from knowing what alleged conduct with what alleged person formed the basis of this Indictment and allows for multiple variances of proof at any trial.
Random acts are disbursed throughout the indictment, some tied to generic alleged "victims" other to a defined alleged "Minor Victim:"
* "befriend" ¶ 4a;
* "being present" ¶ 7a;
* "groomed" ¶7a;
* "undressing" ¶7a; and
* "took Minor Victim -2 to a movie" ¶ 7b.
The discovery provides to Ms. Maxwell provides no information about when and where the alleged instances of sexual abuse took place. Because there are no dates provided, other than a three-year period beginning (perhaps) 27 years in the past, Ms. Maxwell cannot properly investigate where she and other witnesses were when the alleged crime supposedly occurred.
And because the crimes alleged in Counts One through Four are based largely on vaguely stated,
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