033.pdf
488 KB
Extraction Summary
9
People
3
Organizations
4
Locations
3
Events
4
Relationships
5
Quotes
Document Information
Type:
Legal filing (reply in support of motion to quash)
File Size:
488 KB
Summary
This document is a Reply Memorandum filed by attorney Bradley J. Edwards in support of his motion to quash a subpoena served on him by Ghislaine Maxwell. Edwards argues that Maxwell's requests for his communications with 'prospective witnesses' are overbroad, unduly burdensome, and seek protected attorney work-product. The filing notably alleges that Maxwell has failed to explain her presence on 23 flights with a teenaged Virginia Giuffre or the message pads documenting underage girls calling Epstein's mansion for 'massages'.
People (9)
| Name | Role | Context |
|---|---|---|
| Bradley J. Edwards | Plaintiff / Non-party Respondent |
Attorney for Virginia Giuffre; filer of this motion to quash subpoena.
|
| Ghislaine Maxwell | Defendant |
Issued the subpoena to Edwards; accused of recruiting underage girls for Epstein.
|
| Virginia Giuffre | Plaintiff (underlying action) |
Client of Edwards and Cassell; victim/survivor alleging abuse by Epstein and Maxwell.
|
| Paul G. Cassell | Attorney |
Attorney for Plaintiff Bradley J. Edwards; Co-counsel for Giuffre; designated as a 'witness' by Maxwell.
|
| Jeffrey Epstein | Alleged Perpetrator |
Deceased financier; mentioned in context of sexual abuse, private jet flights, and message pads.
|
| Robert W. Sweet | Judge |
US District Court Judge overseeing the case.
|
| Laura A. Menninger | Attorney |
Attorney for Ghislaine Maxwell; recipient of service.
|
| Jeffrey S. Pagliuca | Attorney |
Attorney for Ghislaine Maxwell; recipient of service.
|
| Judge Marra | Judge |
Judge in Southern District of Florida presiding over related case 'Jane Does v. United States'.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of New York |
Court where the motion was filed.
|
|
| S.J. Quinney College of Law at the University of Utah |
Affiliation of attorney Paul G. Cassell.
|
|
| Haddon, Morgan and Foreman, P.C. |
Law firm representing Ghislaine Maxwell.
|
Timeline (3 events)
2016-06-13
Edwards filed motion to quash in Southern District of Florida
Southern District of Florida
Past (Undated)
23 flights on Epstein’s private jet involving Ghislaine Maxwell and a teenaged Ms. Giuffre
Epstein's private jet
Locations (4)
| Location | Context |
|---|---|
|
Jurisdiction of the court.
|
|
|
Home judicial district of Edwards; location of related case 'Jane Does v. United States'.
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Address for Paul G. Cassell.
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Address for Maxwell's attorneys.
|
Relationships (4)
Edwards is described as 'attorney for the Plaintiff' and Giuffre is the client.
Described as working together as co-counsel for more than eight years.
Document mentions Maxwell's involvement in Epstein's sexual abuse and recruitment of females.
Mentions Maxwell on 23 flights with 'teenaged Ms. Giuffre'.
Key Quotes (5)
"Defendant has yet to explain what she was doing on 23 flights on Epstein’s private jet with a teenaged Ms. Giuffre."Source
033.pdf
Quote #1
"Nor has Defendant explained the message pads showing not only Defendant’s presence in Epstein’s mansion but numerous underage girls leaving phone messages in connection with 'massages' to be provided at the home."Source
033.pdf
Quote #2
"Defendant has not disclosed the names of the numerous females she recruited for Jeffrey Epstein"Source
033.pdf
Quote #3
"Maxwell continues to fail to substantively or effectively address the arguments that Edwards presents regarding why the subpoena creates an undue burden on him."Source
033.pdf
Quote #4
"Defendant has failed in her Rule 26 disclosures to identify virtually any of the underage females who could provide testimony in this case – forcing Ms. Giuffre’s attorneys to track them down."Source
033.pdf
Quote #5
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