711.pdf
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- pdf
- Source set
- house-oversight-doj
- Pages
- 11
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- Searchable text available
- OCR confidence
- 0.928288599217397
Original source
Extracted text
Case 1:20-cr-00330-PAE Document 711 Filed 07/12/22 Page1ofi1 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007 December 16, 2021 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 82 20 Cr. 330 (AJN) Dear Judge Nathan: The parties respectfully submit this joint table reflecting the remaining statements about which the parties disagree. The parties have omitted from this table the statements from previous tables in which the parties have reached agreement. The parties note that many of these statements raise one of two questions: (1) must counsel show the witness the prior inconsistent statement under Rule 613(b), and (2) is a statement admissible when the witness affirms that the 3500 material contains the inconsistent statement and also expresses disagreement with the substance. A. Jane Trial 3500 Quote Government Defense Testimony Material Position Position 1 DOJ-OGR-00011289
Case 1:20-cr-00330-PAE Document 711 Filed 07/12/22 Page 2 of 11 447:2 — 447:20 455:3 — 18 470:21 — 471:18 471:18 — 22 3509-002, p. 1 3509-008, p. 12, 4th paragraph 3509-005, p. 3, first paragraph 3509-008, omission GM walked by w/ dog. JE came up to meet her. They visited Jane one to two times at her house in Florida. This was about a year or two after meeting him. Fairly early on Maxwell ‘joined in’ and started taking her clothes off. This was about six months into being with them. Jane was still 14 at this time. Jane does not have a specific memory of the first time. Objection. The shorthand notes in 3509-002 was turned into an FBI 302 which makes clear that the statement was consistent. See 3509-001 p.1, second paragraph. Objection. Not inconsistent with the witness’s testimony, and when confronted with the statement, she …
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