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1.21 MB
Extraction Summary
11
People
7
Organizations
3
Locations
2
Events
5
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
1.21 MB
Summary
This legal document, dated March 22, 2021, is a filing in a criminal case arguing against the Defendant's (Ghislaine Maxwell) discovery requests. The filing contends that requests for communications about co-conspirator Jean Luc Brunel, fee agreements with victims Annie and Maria Farmer, Annie Farmer's complete teenage journal, and materials from the Epstein Victim's Compensation Program are irrelevant and improper 'fishing expeditions' for impeachment material. The document cites case law to assert that the Defendant has failed to demonstrate the relevance and admissibility of the requested evidence.
People (11)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Honorable (Judge) |
The document is addressed to The Honorable Alison J. Nathan.
|
| Jean Luc Brunel | Co-conspirator |
Mentioned as being incarcerated in France, a co-conspirator of Jeffrey Epstein and the Defendant, and the subject of ...
|
| Jeffrey Epstein |
Mentioned as a co-conspirator with Jean Luc Brunel and the Defendant. Also mentioned in relation to Annie Farmer's jo...
|
|
| Annie Farmer | Victim/Witness |
Subject of discovery requests for engagement letters with BSF and her teenage journal. Represented by BSF.
|
| Maria Farmer | Victim/Witness |
Sister of Annie Farmer, also represented by BSF. Mentioned as not being one of the minor victims in the indictment.
|
| L. Menninger |
Author of a letter cited in the case 'Annie Farmer v. Darren K. Indyke, et al.'
|
|
| Debra C. Freeman | Honorable (Judge) |
Recipient of a letter from L. Menninger in a cited case.
|
| Darren K. Indyke | Defendant in a civil action |
Named in the case citation 'Annie Farmer v. Darren K. Indyke, et al.'
|
| Ghislaine Maxwell | Defendant |
Referred to as 'the Defendant' throughout the document. Mentioned by name in a quote regarding Annie Farmer's diary.
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| Pena |
Party in a cited case, 'Pena, 2016 WL 8735699'.
|
|
| Aguilar |
Party in a cited case, 'United States v. Aguilar'.
|
Organizations (7)
| Name | Type | Context |
|---|---|---|
| BSF | Law firm |
Represents Annie and Maria Farmer. The Defendant seeks communications and engagement letters involving BSF.
|
| U.S. Attorney | Government agency |
The Defendant seeks communications between BSF and the U.S. Attorney regarding Jean Luc Brunel.
|
| Government | Government agency |
Mentioned as a source from which documents are procurable.
|
| Epstein Victim’s Compensation Program | Compensation fund |
BSF submitted claims to this program on behalf of Epstein survivors. The Defendant seeks material from this program (...
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| MDC | Detention center |
Mentioned in a case citation ('Pena') regarding records of cooperators.
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| MCC | Detention center |
Mentioned in a case citation ('Pena') regarding records of cooperators.
|
| DOC | Government agency |
Likely Department of Corrections, mentioned in a case citation ('Pena') regarding records of cooperators.
|
Timeline (2 events)
1995
Jeffrey Epstein held Annie Farmer's hand in a movie theater, which made her feel uncomfortable.
movie theater
Locations (3)
Relationships (5)
The document explicitly refers to Maria Farmer as Annie Farmer's 'sister'.
The document states that BSF represents Annie Farmer and that the Defendant is seeking their engagement letters.
The document states that BSF represents Maria Farmer and that the Defendant is seeking their engagement letters.
The document describes Brunel as 'one of Jeffrey Epstein and the Defendant’s co-conspirators'.
The document describes Brunel as 'one of Jeffrey Epstein and the Defendant’s co-conspirators'.
Key Quotes (3)
"[P]laintiff produced certain pages from a diary dated in early 1996 which detailed, only, that Jeffrey Epstein had held her hand in a movie theater in late 1995 which made her feel uncomfortable. This same diary contained exactly zero references to Ghislaine Maxwell, contrary to the assertions in her Complaint . . . ."Source
— L. Menninger (in a letter)
(Quoted from a letter in a prior civil case to argue that the remainder of Annie Farmer's journal is irrelevant.)
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Quote #1
"Pena has failed to make the requisite showing regarding the admissibility of ‘any and all’ other records regarding the cooperators that might exist at the MDC, MCC, or DOC."Source
— Nathan, J.
(Cited from the 'Pena' case to argue that the Defendant must demonstrate the relevance and admissibility of evidence sought via subpoena.)
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Quote #2
"Thus, while the Aguilars have sought some relevant evidence here,"Source
— Court in United States v. Aguilar
(Cited from the 'Aguilar' case, likely to contrast with the current Defendant's request.)
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Quote #3
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