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762 KB
Extraction Summary
3
People
3
Organizations
1
Locations
3
Events
2
Relationships
3
Quotes
Document Information
Type:
Court document (defense motion/memorandum)
File Size:
762 KB
Summary
This legal filing (Page 14 of a defense motion) argues against joining 'Perjury Counts' with 'Mann Act Counts' in the trial of Ghislaine Maxwell. The defense asserts that joining the charges would cause prejudice by introducing uncharged allegations from 1999-2002 involving Virginia Giuffre. The document emphasizes that a previous Palm Beach Police investigation interviewed over 30 victims who did not implicate Maxwell, and notes that the 2019 indictment charged Epstein alone.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the motion arguing against joining perjury counts; defense claims she was cleared by previous investigations.
|
| Virginia Giuffre | Accuser/Alleged Victim |
Her allegations against Maxwell are discussed as the basis for the perjury counts and defamation action.
|
| Jeffrey Epstein | Co-conspirator (Alleged) |
Mentioned regarding his sexual abuse investigation and 2019 indictment.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Palm Beach Police Department |
Investigated Epstein's abuse in the early-mid 2000s; defense claims they found no evidence against Maxwell.
|
|
| District Court |
Where the defamation case and substantive motions were pending.
|
|
| DOJ |
Department of Justice (indicated by Bates stamp DOJ-OGR).
|
Timeline (3 events)
1999-2002
Alleged conspiracy period involving Giuffre.
Unspecified
2019
Indictment charging Epstein alone with sex trafficking offenses (2002-2005).
Unspecified
Jeffrey Epstein
The Government
Early-mid 2000s
Palm Beach Police Department investigation into Epstein.
Palm Beach
Locations (1)
| Location | Context |
|---|---|
|
Location of the Police Department that investigated Epstein.
|
Relationships (2)
Document discusses alleged conspiracy and joint investigations.
Mentions Giuffre's allegations against Maxwell and the defamation case.
Key Quotes (3)
"The Palm Beach Police Department thoroughly investigated allegations of Epstein’s sexual abuse in the early-mid 2000s and did not find any evidence against Ms. Maxwell."Source
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Quote #1
"The documents produced in discovery show that none of the more than 30 alleged victims who were interviewed in that investigation testified that they met, talked to, or identified Ms. Maxwell as someone involved with Epstein’s alleged scheme."Source
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Quote #2
"Moreover, had the government credited Ms. Giuffre’s allegations against Ms. Maxwell, it would no doubt have charged Ms. Maxwell in the 2019 indictment, which charged Epstein alone with sex trafficking offenses from 2002-2005."Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,219 characters)
Case 1:20-cr-00330-AJN Document 120 Filed 01/25/21 Page 14 of 19
about an alleged conspiracy from 1999-2002 were in fact lies, even though the Mann Act Counts
have nothing to do with Giuffre and are based on an entirely separate time period. The jury will
also need to be instructed on the elements of civil defamation and the various defenses, and they
will need to evaluate whether the alleged perjurious statements were material to the defamation
action. At the time the defamation case was dismissed, more than 50 substantive motions were
pending before the District Court. Resolution of the materiality question would necessarily
involve adjudicating those motions. Accordingly, joining the Perjury Counts would substantially
lengthen the trial and unnecessarily complicate the factual issues put before the jury; it would not
serve the goals of trial efficiency and judicial economy, which joinder is supposed to promote.
See Turoff, 853 F.2d at 1042-43; Werner, 620 F.2d at 928; Halper, 590 F.2d at 430.
have nothing to do with Giuffre and are based on an entirely separate time period. The jury will
also need to be instructed on the elements of civil defamation and the various defenses, and they
will need to evaluate whether the alleged perjurious statements were material to the defamation
action. At the time the defamation case was dismissed, more than 50 substantive motions were
pending before the District Court. Resolution of the materiality question would necessarily
involve adjudicating those motions. Accordingly, joining the Perjury Counts would substantially
lengthen the trial and unnecessarily complicate the factual issues put before the jury; it would not
serve the goals of trial efficiency and judicial economy, which joinder is supposed to promote.
See Turoff, 853 F.2d at 1042-43; Werner, 620 F.2d at 928; Halper, 590 F.2d at 430.
A joint trial with the Perjury Counts would also substantially prejudice Ms. Maxwell
because it would necessarily introduce allegations of purported sex abuse from 1999-2002 for
which Ms. Maxwell has never been charged criminally and which is well outside of the time
period alleged in the Mann Act Counts. The Palm Beach Police Department thoroughly
investigated allegations of Epstein’s sexual abuse in the early-mid 2000s and did not find any
evidence against Ms. Maxwell. The documents produced in discovery show that none of the
more than 30 alleged victims who were interviewed in that investigation testified that they met,
talked to, or identified Ms. Maxwell as someone involved with Epstein’s alleged scheme.
Moreover, had the government credited Ms. Giuffre’s allegations against Ms. Maxwell, it would
no doubt have charged Ms. Maxwell in the 2019 indictment, which charged Epstein alone with
sex trafficking offenses from 2002-2005. It did not. Allowing the government to introduce
purported evidence of an uncharged and unsubstantiated conspiracy with Epstein through the
vehicle of the Perjury Counts would be extremely prejudicial and create a substantial risk that the
because it would necessarily introduce allegations of purported sex abuse from 1999-2002 for
which Ms. Maxwell has never been charged criminally and which is well outside of the time
period alleged in the Mann Act Counts. The Palm Beach Police Department thoroughly
investigated allegations of Epstein’s sexual abuse in the early-mid 2000s and did not find any
evidence against Ms. Maxwell. The documents produced in discovery show that none of the
more than 30 alleged victims who were interviewed in that investigation testified that they met,
talked to, or identified Ms. Maxwell as someone involved with Epstein’s alleged scheme.
Moreover, had the government credited Ms. Giuffre’s allegations against Ms. Maxwell, it would
no doubt have charged Ms. Maxwell in the 2019 indictment, which charged Epstein alone with
sex trafficking offenses from 2002-2005. It did not. Allowing the government to introduce
purported evidence of an uncharged and unsubstantiated conspiracy with Epstein through the
vehicle of the Perjury Counts would be extremely prejudicial and create a substantial risk that the
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DOJ-OGR-00002292
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