2023.10.03%20Response.pdf
2.54 MB
Extraction Summary
10
People
9
Organizations
7
Locations
2
Events
2
Relationships
6
Quotes
Document Information
Type:
Legal filing - plaintiff's response to status hearing
File Size:
2.54 MB
Summary
In this May 2023 filing to the Superior Court of the Virgin Islands, a pro se incarcerated Ghislaine Maxwell requests a 180-day stay in her civil suit for indemnification against the Estate of Jeffrey Epstein. Maxwell argues she needs time to find new counsel following her previous attorney's withdrawal, citing severe communication restrictions and lack of access to legal resources (computers, state case law) within FCI Tallahassee. She also argues the civil case should be paused pending the outcome of her criminal appeal (2nd Circuit Case 22-14626-CR) and cites a 2002 lawsuit (Shanks v. Wexner) as evidence that Epstein historically indemnified her for legal costs.
People (10)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Plaintiff |
Pro Se litigant, currently incarcerated inmate (ID #02879-509), seeking indemnification from Epstein's estate.
|
| Jeffrey E. Epstein | Deceased / Subject of Estate |
Former employer of Maxwell; his estate is the defendant.
|
| Darren K. Indyke | Defendant / Co-Executor |
Sued in his capacity as Co-Executor of the Estate of Jeffrey E. Epstein.
|
| Richard D. Kahn | Defendant / Co-Executor |
Sued in his capacity as Co-Executor of the Estate of Jeffrey E. Epstein.
|
| Kyle R. Waldner | Former Attorney |
Former attorney for Maxwell who withdrew from the case.
|
| Nelson Shanks | Plaintiff (Historical) |
Plaintiff in a 2002 lawsuit (Shanks v. Wexner et al) cited by Maxwell as evidence of prior indemnification.
|
| Leslie Wexner | Defendant (Historical) |
Defendant in the 2002 Shanks lawsuit alongside Epstein and Maxwell.
|
| Abigail Wexner | Defendant (Historical) |
Defendant in the 2002 Shanks lawsuit.
|
| Megan G. Marlow | Attorney / BOP Staff |
Signed the response denying Maxwell access to Virgin Islands case law in prison.
|
| Ariel M. Smith | Assistant Attorney General |
Recipient of the certificate of service at the Virgin Islands Dept of Justice.
|
Organizations (9)
Timeline (2 events)
2023-02-28
Filing of Criminal Appeal (Case 22-14626-CR)
United States Court of Appeals for the Second Circuit
2023-03-17
Status Hearing
Superior Court of the Virgin Islands
Relationships (2)
Maxwell claims indemnification for legal fees based on 'prior employment relationship' and cites past instances where Epstein indemnified her (Shanks lawsuit).
Maxwell argues regarding the NES 2014 Operating Agreement and claims indemnification rights.
Key Quotes (6)
"She only has access to US Postal Service as an inmate"Source
2023.10.03%20Response.pdf
Quote #1
"Plaintiff has no access to a computer to type any document per court norms... no internet access to do research"Source
2023.10.03%20Response.pdf
Quote #2
"Epstein is quoted saying in part of the interview, 'it's, it's just unfair because she (Plaintiff) really plays no role, and Ghislaine was never, never ever a apart of any of this stuff.'"Source
2023.10.03%20Response.pdf
Quote #3
"Plaintiff has no ability to write snail mail, E Mall, or call any potential new attorney with client attorney privilege."Source
2023.10.03%20Response.pdf
Quote #4
"Plaintiff seeks more time to read the relevant law and statutes so she can respond to court orders"Source
2023.10.03%20Response.pdf
Quote #5
"Once under the aegis of BOP an inmate enters a veritable technological black hole"Source
2023.10.03%20Response.pdf
Quote #6
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