EFTA00022960.pdf

1.28 MB
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Extraction Summary

20
People
11
Organizations
6
Locations
2
Events
3
Relationships
5
Quotes

Document Information

Type: Legal filing (objections to unsealing and memorandum brief)
File Size: 1.28 MB
Summary

This document is a legal filing by Ghislaine Maxwell's defense team objecting to the unsealing of specific docket entries (143, 173, 199, 164, and 230) in the civil case brought by Virginia Giuffre. The defense argues that these documents contain sensitive information regarding non-parties ('Does'), inadmissible hearsay, and prejudicial materials such as flight logs and police reports that were improperly filed to bias the court. The filing emphasizes the need to protect the privacy of non-parties and the integrity of ongoing criminal investigations into Jeffrey Epstein's conduct.

People (20)

Name Role Context
Ghislaine Maxwell Defendant
Objecting to the unsealing of sensitive documents
Virginia L. Giuffre Plaintiff
Party seeking unsealing/discovery
Jeffrey Epstein Deceased
Referred to as Mr. Epstein, subject of ongoing criminal investigations
Laura A. Menninger Attorney
Counsel for Ghislaine Maxwell
Jeffrey S. Pagliuca Attorney
Counsel for Ghislaine Maxwell
Ty Gee Attorney
Counsel for Ghislaine Maxwell
Sigrid S. McCawley Attorney
Counsel for Plaintiff
Meredith Schultz Attorney
Counsel for Plaintiff
Bradley J. Edwards Attorney
Counsel for Plaintiff
Stan J. Pottinger Attorney
Counsel for Plaintiff
Paul G. Cassell Attorney
Counsel for Plaintiff
Andrew G. Celli Attorney
Service recipient
David Lebowitz Attorney
Service recipient
Christine N. Walz Attorney
Service recipient
Jay M. Wolman Attorney
Service recipient
Marc J. Randazza Attorney
Service recipient
Nicole Simmons Signatory
Signed Certificate of Service
Does 1 and 2 Non-Parties
Individuals mentioned in sealed materials
J. Doe 1 Non-Party
Subject of hearsay statements in exhibits, medically unable to recall events
Non-Party Does Witnesses/Third Parties
Numerous unidentified individuals referenced in sealed documents

Timeline (2 events)

Unknown date
Deposition of Ghislaine Maxwell
Unknown
Ghislaine Maxwell Attorneys
Unknown date
Deposition of J. Doe 1
Unknown

Relationships (3)

Plaintiff vs Defendant in lawsuit
Referenced in context of investigations surrounding his conduct
J. Doe 1 Witness/Non-Party Ghislaine Maxwell
Subject of hearsay exhibits, never examined by Maxwell's counsel

Key Quotes (5)

"This series of pleadings concerns Plaintiff’s attempt to compel Ms. Maxwell to answer intrusive questions about her sex life."
Source
EFTA00022960.pdf
Quote #1
"The attachment of alleged summaries of flight logs, alleged flight logs, and police reports was simply a mechanism to attempt to bias the Court and any potential future reader of the material."
Source
EFTA00022960.pdf
Quote #2
"Exhibits 4 and 7 are inadmissible hearsay transcripts from an unreliable deceased individual never deposed by Ms. Maxwell."
Source
EFTA00022960.pdf
Quote #3
"Ms. Maxwell is aware... that investigations surrounding the alleged conduct of Mr. Epstein survive his death."
Source
EFTA00022960.pdf
Quote #4
"Materials that cause annoyance, embarrassment, oppression or undue burden to an individual should be sealed or redacted."
Source
EFTA00022960.pdf
Quote #5

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