DOJ-OGR-00019318.jpg
1.25 MB
Extraction Summary
6
People
7
Organizations
4
Locations
6
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
1.25 MB
Summary
This legal document, dated May 18, 2020, is a filing arguing against defendant Maxwell's request to stay discovery in a civil case. The author contends that Maxwell has failed to justify the stay based on a parallel criminal investigation and that a potential claims resolution program involving co-defendant Epstein's Estate does not require litigation to be paused. The filing cites court transcripts and case law to support the position that discovery should proceed, as it may even be necessary to facilitate settlement.
People (6)
| Name | Role | Context |
|---|---|---|
| Debra C. Freeman | Honorable |
Addressed at the top of the document: 'The Honorable Debra C. Freeman'.
|
| Maxwell | Defendant |
Mentioned throughout the document as the defendant seeking a stay of discovery.
|
| Epstein | Co-conspirator |
Mentioned in relation to a criminal investigation into his co-conspirators and his Estate.
|
| Jeffrey Epstein |
Mentioned in relation to the criminal activity lien on his Estate and in a case name.
|
|
| Rex & Roberta Ling |
Mentioned in the case citation 'Rex & Roberta Ling Living Tr. v. B Commc’ns Ltd.'.
|
|
| Willie |
Mentioned in the case citation 'Willie v. Amerada Hess Corp.'.
|
Organizations (7)
| Name | Type | Context |
|---|---|---|
| Southern District | government agency |
Mentioned in relation to its criminal investigation.
|
| Rex & Roberta Ling Living Tr. | trust |
Mentioned in a case citation.
|
| B Commc’ns Ltd. | company |
Mentioned in a case citation.
|
| Epstein's Estate | estate |
Mentioned as Maxwell's co-defendant and subject to a criminal activity lien and a potential claims resolution program.
|
| USVI Attorney General | government agency |
Mentioned as negotiating with Epstein's Estate regarding a claims resolution program.
|
| Amerada Hess Corp. | company |
Mentioned in a case citation.
|
| DOJ-OGR | government agency |
Appears in the footer of the document (DOJ-OGR-00019318).
|
Timeline (6 events)
2019-11-21
A court conference where the need for discovery for settlement and the court's default position against stays were discussed.
Court
2020-02-11
A court conference where the stay of discovery and the claims resolution program were discussed.
Court
Epstein's Estate
A criminal investigation into Epstein's co-conspirators by the Southern District.
Southern District
Southern District
Epstein's co-conspirators
A 'meet and confer' between Plaintiff's counsel and Maxwell's counsel regarding the criminal investigation.
Plaintiff's counsel
Maxwell's counsel
A potential claims resolution program involving Jeffrey Epstein's Estate.
U.S. Virgin Islands
Epstein's Estate
victims
Negotiations between the USVI Attorney General and Epstein's Estate over the scope of release for participants in the claims resolution program.
Locations (4)
| Location | Context |
|---|---|
|
Referenced in relation to an investigation.
|
|
|
Mentioned in a case citation, referring to the Southern District of New York.
|
|
|
Mentioned as the location of a criminal activity lien on Jeffrey Epstein's Estate. Abbreviated as 'USVI'.
|
|
|
Mentioned in a case citation, referring to the Virgin Islands Superior Court.
|
Relationships (2)
The document mentions a 'criminal investigation into Epstein’s co-conspirators' in the context of Maxwell's case.
The document explicitly states 'Epstein’s Estate (Maxwell’s co-defendant)'.
Key Quotes (5)
"A civil defendant urging such a stay [pending a parallel criminal prosecution] bears the burden of establishing its need."Source
— Rex & Roberta Ling Living Tr. v. B Commc’ns Ltd.
(Quoted from a 2018 S.D.N.Y. case to argue that Maxwell has not met the burden to justify a stay.)
DOJ-OGR-00019318.jpg
Quote #1
"[T]he two cases where discovery has been stayed, in light of what’s happening in the Virgin Islands, they may end up unstayed."Source
— Court Conference Transcript
(Quoted from a Feb. 11, 2020 conference transcript regarding the effect of the criminal lien in the USVI.)
DOJ-OGR-00019318.jpg
Quote #2
"The default in this Court is that it does not stay discovery."Source
— Court Conference Transcript
(Quoted from a Nov. 21, 2019 conference transcript to state the court's general policy.)
DOJ-OGR-00019318.jpg
Quote #3
"[I]t may be that you need discovery in the litigation to have in hand certain discovery before you can figure out the right settlement for a particular case."Source
— Court Conference Transcript
(Quoted from a Nov. 21, 2019 conference transcript to argue that discovery may be necessary to facilitate settlement.)
DOJ-OGR-00019318.jpg
Quote #4
"where an innocent party is held vicariously liable for the actions of the true tortfeasor"Source
— Willie v. Amerada Hess Corp.
(Quoted from a 2017 case in a footnote to explain the conditions for common law indemnification, which Maxwell sought from Epstein's Estate.)
DOJ-OGR-00019318.jpg
Quote #5
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