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Extraction Summary

10
People
4
Organizations
5
Locations
2
Events
4
Relationships
4
Quotes

Document Information

Type: Legal document
File Size: 914 KB
Summary

This legal document, dated March 22, 2021, is a submission by Sigrid S. McCawley arguing against a defendant's motion to subpoena evidence from a third party, BSF. The document contends that the requested materials—including communications, a Grand Jury subpoena, cowboy boots, and photographs involving individuals like Annie Farmer, Virginia Giuffre, and Jeffrey Epstein—are either obtainable from the government or not relevant enough to require pre-trial production. The author concludes that the defendant's motion should be denied.

People (10)

Name Role Context
Alison J. Nathan The Honorable
The document is addressed to The Honorable Alison J. Nathan.
Sigrid S. McCawley
The author who respectfully submitted and signed the document.
Annie Farmer
Mentioned in Request 10 regarding a pair of cowboy boots purchased for her, and in Request 11 regarding photographs o...
Jeffrey Epstein
Mentioned as having purchased cowboy boots for Annie Farmer with the Defendant, and as the owner of properties where ...
Maria Farmer
Mentioned in Request 11 regarding photographs of her on Leslie Wexner's property.
Leslie Wexner
Mentioned as the owner of a property where photographs of Maria Farmer were taken.
Virginia Giuffre
Mentioned in Request 11 regarding photographs of her on Jeffrey Epstein's and the Defendant's properties, and with Pr...
Prince Andrew
Mentioned in Request 11 regarding a photograph with Virginia Giuffre and the Defendant.
The Defendant Defendant
The subject of the legal filing, who is seeking to obtain documents and items via subpoena. Mentioned throughout the ...
The Farmers
A collective reference to Annie Farmer and Maria Farmer, mentioned as potential witnesses who may testify.

Organizations (4)

Name Type Context
BSF company
The entity from which the Defendant seeks to obtain documents via a subpoena.
Government government agency
Referred to as the source from which the Defendant can procure certain documents, instead of from BSF.
U.S. Attorney government agency
Mentioned in relation to communications sought by the Defendant from BSF.
United States Attorney’s Office government agency
Cited as an alternative source for documents the Defendant seeks.

Timeline (2 events)

2021-03-30
Document 191 was filed in Case 1:20-cr-00330-PAE.
The Defendant's motion to authorize service of the Subpoena on BSF.

Locations (5)

Location Context
Location where photographs of Maria Farmer were allegedly taken.
Location where photographs of Virginia Giuffre were allegedly taken.
Location where photographs of Virginia Giuffre were allegedly taken.
Location where photographs of Virginia Giuffre, Prince Andrew, and the Defendant were allegedly taken.
Southern District of New York, mentioned in legal citations (United States v. Bergstein and United States v. Boyle).

Relationships (4)

The Defendant associates Jeffrey Epstein
They jointly purchased a pair of cowboy boots for Annie Farmer.
The Defendant acquaintances Virginia Giuffre
A photograph allegedly exists of them together with Prince Andrew in the Defendant's London townhome. Photographs of Giuffre were also allegedly taken on the Defendant's properties.
The Defendant acquaintances Prince Andrew
A photograph allegedly exists of them together with Virginia Giuffre in the Defendant's London townhome.
Maria Farmer unspecified Leslie Wexner
A photograph of Maria Farmer was allegedly taken on Leslie Wexner's property.

Key Quotes (4)

"otherwise procurable"
Source
— Nixon, 418 U.S. at 699 (Used to argue that documents sought from BSF are available from the Government.)
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Quote #1
"When ‘many’ of the subpoenaed materials are obtainable through the discovery process, a subpoena contravenes Nixon’s requirement that subpoenaed materials must not be otherwise procurable in advance of trial by the exercise of due diligence."
Source
— United States v. Bergstein (A legal citation used to support the argument that the subpoena to BSF is improper.)
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Quote #2
"likely that many of the documents that defendant seeks in his subpoena are obtainable from another source—the United States Attorney’s Office—with little or no diligence required"
Source
— United States v. Boyle (A legal citation used to support quashing a subpoena when materials are available elsewhere.)
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Quote #3
"cannot properly prepare for trial without such production and inspection in advance of trial and that the failure to obtain such inspection may tend unreasonably to delay the trial,"
Source
— Nixon, 418 U.S. at 699 (A requirement under the Nixon standard that the Defendant cannot meet regarding the requested photographs and boots.)
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Quote #4

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