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651 KB
Extraction Summary
3
People
4
Organizations
1
Locations
3
Events
1
Relationships
5
Quotes
Document Information
Type:
Court order / legal opinion (page from a ruling on a motion to dismiss)
File Size:
651 KB
Summary
This document is page 22 of a court ruling (Document 207) filed on April 16, 2021, in the case United States v. Maxwell. The court is denying Maxwell's motion to dismiss perjury counts, arguing that the ambiguity of questions and the materiality of her statements are issues of fact for a jury to decide, not grounds for pretrial dismissal. The text cites legal precedents regarding perjury, materiality in civil depositions, and the role of the jury.
People (3)
| Name | Role | Context |
|---|---|---|
| Maxwell | Defendant |
Subject of the motion; arguing that perjury counts should be dismissed due to ambiguity and lack of materiality.
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| AJN | Judge |
Initials in case number 1:20-cr-00330-AJN, indicating Judge Alison J. Nathan.
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| The Government | Prosecution |
Opposing party presenting evidence.
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States District Court |
Implied by case number and citations.
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| 2d Cir. |
Second Circuit Court of Appeals, cited in case law.
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| S.D.N.Y. |
Southern District of New York, cited in case law.
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| DOJ |
Department of Justice (indicated in footer DOJ-OGR).
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Locations (1)
| Location | Context |
|---|---|
|
Southern District of New York (jurisdiction mentioned in citations).
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Relationships (1)
Legal proceedings where Government evidence opposes Maxwell's motion.
Key Quotes (5)
"At a minimum, Maxwell’s motion is premature."Source
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Quote #1
"None of the alleged ambiguities Maxwell identifies rise to the level supporting dismissal of the charges."Source
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Quote #2
"A reasonable juror could conclude that Maxwell’s statements were material"Source
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Quote #3
"In a civil deposition, a statement is material if it has a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence."Source
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Quote #4
"Truth and falsity are questions for the jury in all but the most extreme cases."Source
DOJ-OGR-00020781.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,206 characters)
Case 22-1426, Document 57, 02/28/2023, 3475900, Page163 of 208
A-159
A-159
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 22 of 34
At a minimum, Maxwell’s motion is premature. Courts typically evaluate whether a
question was fundamentally ambiguous only after the development of a full factual record at
trial. See, e.g., United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992). The evidence at
trial may shed further light on whether the questions posed were objectively ambiguous in
context or whether Maxwell subjectively understood them. In any event, the Court has closely
considered each of the categories of questions that Maxwell argues are ambiguous. None of the
alleged ambiguities Maxwell identifies rise to the level supporting dismissal of the charges. The
context of the questions and answers, in conjunction with the Government’s evidence, could lead
a reasonable juror to conclude that the statements were perjurious. Truth and falsity are
questions for the jury in all but the most extreme cases. The Court declines to usurp the jury’s
role on the limited pretrial record.
question was fundamentally ambiguous only after the development of a full factual record at
trial. See, e.g., United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992). The evidence at
trial may shed further light on whether the questions posed were objectively ambiguous in
context or whether Maxwell subjectively understood them. In any event, the Court has closely
considered each of the categories of questions that Maxwell argues are ambiguous. None of the
alleged ambiguities Maxwell identifies rise to the level supporting dismissal of the charges. The
context of the questions and answers, in conjunction with the Government’s evidence, could lead
a reasonable juror to conclude that the statements were perjurious. Truth and falsity are
questions for the jury in all but the most extreme cases. The Court declines to usurp the jury’s
role on the limited pretrial record.
B. A reasonable juror could conclude that Maxwell’s statements were material
Maxwell also argues that the perjury counts should be dismissed because none of the
allegedly false statements were material to the defamation action. In a civil deposition, a
statement is material if it has a natural tendency to influence the court or if a truthful answer
might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515
U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753–54 (2d Cir. 1994). Like knowing
falsity, materiality is an element of the offense and thus ordinarily must be “decided by the jury,
not the court.” Johnson v. United States, 520 U.S. 461, 465 (1997). Only the most extraordinary
circumstances justify departure from this general rule. United States v. Forde, 740 F. Supp. 2d
406, 412 (S.D.N.Y. 2010) (citing Gaudin, 515 U.S. at 522–23).
allegedly false statements were material to the defamation action. In a civil deposition, a
statement is material if it has a natural tendency to influence the court or if a truthful answer
might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515
U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753–54 (2d Cir. 1994). Like knowing
falsity, materiality is an element of the offense and thus ordinarily must be “decided by the jury,
not the court.” Johnson v. United States, 520 U.S. 461, 465 (1997). Only the most extraordinary
circumstances justify departure from this general rule. United States v. Forde, 740 F. Supp. 2d
406, 412 (S.D.N.Y. 2010) (citing Gaudin, 515 U.S. at 522–23).
The charged statements do not fall within this narrow exception. Maxwell contends that
the questions did not relate to the sex trafficking and sexual abuse allegations at the center of the
the questions did not relate to the sex trafficking and sexual abuse allegations at the center of the
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DOJ-OGR-00020781
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