2023.12.22%20Response.pdf
2.2 MB
Extraction Summary
6
People
7
Organizations
4
Locations
5
Events
4
Relationships
4
Quotes
Document Information
Type:
Legal filing (response to motion to dismiss)
File Size:
2.2 MB
Summary
Ghislaine Maxwell, appearing pro-se, responds to the Defendants' (Estate of Jeffrey Epstein and executors) motion to dismiss her case for failure to prosecute. She argues that she has complied with court orders despite the constraints of incarceration and seeks indemnification for legal expenses based on Virgin Islands common law, corporate law, and the NES LLC operating agreement. She asserts that public policy and the "unclean hands" of the executors should not bar her claims.
People (6)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | ||
| Jeffrey E Epstein | ||
| Darren K Indyke | ||
| Richard D Kahn | ||
| Jennifer Araroz | ||
| Tamara Charles |
Organizations (7)
Timeline (5 events)
Filing of Plaintiff's Response (December 22, 2023)
Plaintiff's original filing of action (March 12, 2020)
Withdrawal of Plaintiff's attorney (September 7, 2022)
Plaintiff's status hearing response (May 16, 2023)
Non-Prosecution Agreement (NPA) creation
Locations (4)
| Location | Context |
|---|---|
Relationships (4)
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Key Quotes (4)
"Ghislaine Maxwell appears pro-se and respectively submits this reply in support of the continued stay in proceedings"Source
2023.12.22%20Response.pdf
Quote #1
"Litigation is deemed filed at the time delivered to prison authority, Houston v LACK"Source
2023.12.22%20Response.pdf
Quote #2
"The co-executors should not raise any objection to indemnification on public policy grounds in addition due to unclean hands."Source
2023.12.22%20Response.pdf
Quote #3
"Epsteins clearly wanted to indemnify his employees as noted by by Indyke and Kahn's indemnification"Source
2023.12.22%20Response.pdf
Quote #4
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